Providing forums for employees to raise questions about business strategy and simplifying compliance policies to be real resource among topics at Ethisphere’s annual ethics summit
There’s a growing consensus that encouraging a speak-up culture within a company is a core requirement for a robust ethics and compliance program. But companies need to ask themselves if they’re really ready to listen to employees’ feedback on a variety of issues, or if it’s just a nice idea, like curiosity in children.
During a plenary session at Ethisphere Institute’s annual Global Ethics Summit, held in New York City on March 9-10, compliance and legal officers from Eli Lilly and Company, LinkedIn, Abercrombie & Fitch and Johnson Controls exchanged thoughts on that topic and others relevant to infusing company culture with ethical values.
Millennials, who are a major part of LinkedIn’s workforce, have no notion of hierarchy and no hesitation to speak up and question companies’ strategies and policies, said LinkedIn’s head of global compliance and integrity, Amyn Thawer, during the plenary session. Every two weeks, senior managers make presentations on the latest developments in the company’s business strategy to LinkedIn’s entire workforce, which are followed by a Q&A session. During one recent meeting, an employee questioned the acquisition strategy, which creates a sense of accountability for senior executives, Thawer said.
‘Talent is our number one priority and there’s fierce competition for talent,’ he explained. ‘So, if they question our strategy, we’re in trouble.’
But apparently at Abercrombie & Fitch, certain questions from employees are more welcome than others. General counsel and corporate secretary Robert Bostrom spoke about the need to ‘co-opt and influence employees into the company culture’ and speaking up. But, he added, ‘they need help understanding what to speak up about.’ That left attendees to speculate about how senior management might handle staffer queries about elitist brand image mongering and resistance to discounting during hard economic times.
At Johnson Controls, members of the C-suite understand that while the company’s ‘cultural ecosystem’ comprises both formal and informal systems, it’s the latter that have the most daily impact on the work environment, said Brian Beeghly, vice president of compliance. ‘The manager or supervisor has a disproportionate impact on these informal systems,’ he said, adding that signs of disconnects between a manager’s behavior and stated company culture isn’t necessarily proof of misconduct, however.
The panel also acknowledged that when a company’s compliance policies became overloaded with technical legal language and unwieldy, they become a source of frustration to employees rather than a helpful resource to employees. For the past 18 months, Eli Lilly and Company has been making efforts to simplify its corporate policies, which were designed more with outside regulators in mind than employees, said Melissa Stapleton Barnes, chief ethics and compliance officer and head of enterprise risk management. She likened the former policies to the tax code, consisting of hundreds of pages of minute legal detail.
The revised policies are designed to foster a principles-based culture instead of one based on rules, Barnes said. ‘Rules inadvertently teach people to look for loopholes when we should be helping them better understand principles.’ Overhauling its corporate policies has created a platform for communication campaigns that enable the top executives to make it clear they want employees to ask questions and raise any concerns they have, she adds.
Citing the increased attention that compliance professionals are giving to improving ‘tone at the middle’, Beeghly said managers’ hiring processes need to take personal integrity and the ability to serve as a role model into account. By asking questions designed to screen for integrity and ethical behavior, hiring managers can send a message to job candidates that the company takes ethics seriously. These same considerations can also be built into assessments for promotion, but he added that this is a long-term process and there is no simple fix that will change it.
