Compliance & Ethics Professional - Society of Corporate ...

highly individualized. Leaders may find thatthey have removed the specific actor, but havedone little to alter the forces which motivatedthe undesirable act.which the ethical principles, guidelines, andprocesses of the organization are integratedwithin the organizational system.There are innumerable variations inbetween the two extremes, and each type ofassessment is progressively more complex andoffers the client a set of data which is morecomprehensive. There is nothing wrong withany of them. Each serves a different purpose.What is wrong is when clients’ needs arenot served because they have received thewrong assessment for their desired outcomes.If, for example, the client organization has anexisting program to prevent and detect ethicsviolations and merely wishes to ensure that theprogram satisfies the requirements specifiedin the current iteration of Federal SentencingGuidelines for ethics violations, then a complianceassessment is an appropriate response.If the client suspects intentional orunintentional wrongdoing and wants tounderstand why it is occurring, then a culturalor systems assessment may be a better choice.One limitation of the compliance-orientedapproach is the difficulty managers may haverecognizing themselves in the findings andaccepting responsibility. Compliance assessmentsare narrowly focused and representa high degree of vulnerability to anyoneidentified as “out of compliance.” Thus,many leaders go to great lengths to distancethemselves from these types of findings.Interestingly, an organization’s first responseto negative findings is often punitive andGoing beyond complianceIf the organization wants to address the rootcauses of unethical behavior, then a systemsassessment may be the more effective alternative.For some, a compliance assessment maybe all that they know to ask for. These managersmay not appreciate what else might beaccomplished through a culture- or systemsfocusedethics assessment. Their assessor,especially if that service provider is a legalor financial professional, also may not knowwhat to offer, or have the wherewithal toprovide a more comprehensive and/or appropriateethics assessment alternative.There are two traditional ways to gobeyond a check on organizational and individualcompliance: the cultural assessment andthe systems assessment.Cultural assessments have been usedextensively by management consultants overthe years. They assess perceptions and identifyissues relating to how specific groupsof stakeholders view targeted aspects of anorganization, such as leader effectiveness,decision-making, and change management.Their inherent limitation is that they, like thecompliance assessment, do not identify underlyingcauses.Several years ago, some managementconsulting firms that had become involvedin ethics management, including NavranAssociates, saw the value of applying “systems”methodology to ethics questions (e.g.,employee perceptions of leader integrity, theeffectiveness of ethics policies, confidencein ethics systems, and the effectiveness ofemployee hotlines in informing and changingbehaviors) as a supplement to complianceassessments.Compliance & Ethics Professional March/April 2012+1 952 933 4977 or 888 277 4977 | www.corporatecompliance.org 47