How NW Natural overhauled its ethics code

Jan 23, 2019
Behind NW Natural’s win for best compliance and ethics program (small to mid-cap) at the Corporate Governance Awards

The key project for NW Natural’s compliance and ethics program in 2017 was a detailed and creative overhaul of the company’s code of ethics. It was the first review since 2012 of the code, which the company describes as the foundation of its business integrity program and which applies to all employees and the board of directors.

‘The previous code was short and rule-based, full of thou shalt not language,’ explains Shawn Filippi, vice president, chief compliance officer and corporate secretary. Employees – who are often scattered to sometimes remote locations – were also frequently raising questions about the old code, she adds. The message received was that people learn better from stories and examples than from rules.

The review process was conducted by Filippi’s group in co-ordination with a team of more than 25 individuals from departments including procurement, internal audit, community affairs, governmental affairs, facilities, information technology, HR, legal, operations and communications. In shaping a new, better way of conveying how employees and directors are expected to behave, the group looked at questions it had fielded in previous years and issues raised on the company’s hotline.

It also benchmarked NW Natural’s code against those from 21 of the companies named as the world’s most ethical companies by the Ethisphere Institute, as well as 13 peer companies.

The result was the creation of a 40-minute online module that walks employees through what they need to know. They must complete the training each year, when it is refreshed, but they can go at their own pace and the process involves games and other interactive features. The team also created a new written code, which features Q&A sections and ‘Did you know?’ information.

For a code to be effective, it also needs to have high visibility among employees. ‘It’s not the business integrity group that owns compliance and ethics – everybody does,’ Filippi says. NW Natural’s new code had a high-profile launch in early 2018 that included management presentations, a promotional breakfast, trivia contests and promotional materials, including pop-sockets, T-shirts, coffee mugs and ‘magic integrity balls’ – Magic 8-Balls directing employees, for example, to the business integrity team or company hotline.

The feedback has been overwhelmingly positive, Filippi says. Employees have welcomed the interactive elements and the ability to take the training at one’s own pace. As well as the annual training, Filippi’s team develops 10-minute online modules on emerging or specific topics such as cyber-security. For example, a slight uptick in anonymous reporting, which can suggest concerns over retaliation, prompted the company to create an online training module for managers to ensure they know how to avoid retaliation and how to address it.

This article originally appeared in the latest Corporate Secretary special report. Click here to view the full publication.

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