Joe Murphy – Compliance & Ethics Professional – May 2016
Culture is important in compliance and ethics. In our companies, we want cultures that support ethical conduct and compliance with law, but addressing culture is not enough.
I read a commentary recently making the odd assertion that more controls can lead to more violations; the thesis was that we should instead use behavioral approaches. There was a bit of sense in this, but built on the wrong premise. Anything done wrong can lead to bad results. Ham-handed controls can backfire. But so can poorly-designed behavioral approaches. No matter what approach you take, you need to learn from experience, watch what you are doing, and listen carefully to your people.
I am a fan of behavioral tools and believe we should use them. But, even if your culture is wonderful and 86% of your people love the company, trust their leaders, and are happy to come to work every day, this does not mean you are safe. If 86% are ethical and happy, this can still mean that 14% are not. If this were an election, you would win handily, but corporate crime is not committed by majority vote. One department, one work unit, or even one individual can commit offenses serious enough to ruin a company’s reputation.
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