BUILDING AND REINFORCING

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1 BUILDING AND REINFORCING AN ETHICS-BASED CULTURE BUILDING AND REINFORCING AN ETHICS-BASED CULTURE Joseph Hayes VP Ethics and Business Conduct Assistant General Counsel Service Corporation International October 8, 2013 OVERVIEW I. Why it matters II. What does Doing The Right Thing mean? A. More than just compliance B. Link to organization s mission and values III. Communication and Awareness Campaign IV. Accountability V. Employee Hotlines VI. Town Hall Meetings VII. Role of Chief Ethics & Compliance Officer 2 1

2 REASONS WHY ETHICS-BASED CULTURE MATTERS Influences behavior in a positive direction Enhances reputation Appeals to customers (positive impact on sales) Appeals to employees (positive impact on hiring and retention) Appeals to shareholders Boosts employee morale Protects against unethical behavior public scandals bad PR litigation regulatory sanctions criminal charges lost business 3 2

3 SOCRATES ON REPUTATION WARREN BUFFET ON REPUTATION AND CULTURE The way to gain a good reputation is to endeavor to be what you desire to appear. Our top priority is that all of us continue to zealously guard our Company s reputation. We can afford to lose money even a lot of money. But we can t afford to lose reputation even a shred of reputation. It takes 20 years to build a reputation and five minutes to ruin it. CULTURE, MORE THAN RULE BOOKS, DETERMINES HOW AN ORGANIZATION BEHAVES. 5 3

4 DOING THE RIGHT THING Need to define what that means in your organization More than just avoiding lying, cheating and stealing More than just extreme compliance Consider tying to loftier goals, such as those embedded in Company s values or mission statement Example: Service Excellence COMMUNICATION AND AWARENESS CAMPAIGN Tone at the top: active engagement by senior leadership is key Utilize multiple communication channels: newsletters, video messages, Company intranet site, staff meetings, town hall meetings Consider catchy slogans/signs Peer reviews Create team/committee to help drive and reinforce messaging and to continually develop new ideas Keep at it and keep it fresh 7 8 4

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6 EMPLOYEE RECOGNITION AND REWARD ACCOUNTABILITY Positive recognition for those who demonstrate commitment to Company s culture Associate of the Year (or Quarter) awards Celebrate successes publicly Frontline management must drive this Should be a component of incentive compensation Should be a factor in performance/compensation reviews Must be strong response to employee behavior that is inconsistent with Company s values and ethics

7 EMPLOYEE COMMUNICATION VEHICLES Employees must have means of raising issues when they have ethics-related concerns or questions Complaint hotline to report problems Ethics hotline for seeking guidance on ethical dilemmas or Company policies TOWN HALL MEETINGS REGARDING ETHICS AND COMPANY CULTURE Sends powerful message that Company cares Must be engaging and impactful Ethics/Compliance leader to play key role

8 As you check out at the grocery store, the cashier gives you too much change. You should: ETHICS QUIZ A. Immediately point that out and return the money. B. Quickly pocket the money and walk out of the store as nonchalantly as you can. C. Get back in line and buy more groceries, and hope he gives you too much change again. 8

9 You take your 12-year-old son to a ballgame. The sign at the ticket booth states that children 11 and under are half-price. You should: A. Ask for two adult tickets. B. Tell your son to go wait in line, and once he is out of earshot, ask for one adult ticket and one child s ticket. C. Tell your son to watch and learn how to save some cash and not be a chump, as you order one adult and one child s ticket, telling the cashier your son is 11. Representatives of your company s HR department are visiting your facility and meeting with various employees behind closed doors. You receive a text from the office gossip indicating that she has heard that HR is there because Johnny has been sexually harassing Susie. You should: A. Text everybody in the office to let them know that Johnny has been sexually harassing Susie so that they are not blindsided by HR. B. What a creep! You should , text, tweet and Facebook everyone you know to make sure they are aware of what a dreadful scoundrel Johnny is. C. Just ignore the text message. D. Speak with your colleague about the dangers and impropriety of spreading rumors about a colleague, particularly when you don t have firsthand information of all of the facts. 9

10 BEWARE OF THE SLIPPERY SLOPE: RATIONALIZING INTEGRITY The true test of one s character and integrity is how you behave when no one is watching. 10

11 ROLE OF CHIEF ETHICS AND COMPLIANCE OFFICER IN BUILDING/REINFORCING CULTURE Conscience of the Company Head cheerleader Keep focus on ethics sharp and ongoing Wield influence from Board Room to front line Idea person as well as implementation person BUILDING YOUR BRAND AND ENHANCING EFFECTIVENESS AS CHIEF ETHICS & COMPLIANCE OFFICER Cultivate rapport, respect and influence with all key constituents: senior leadership, line management, frontline employees Build credibility/stature within Company Strive for high visibility through frequent and effective communications Promote Company culture, not just compliance Enhance credentials and stature through outside activities speaking, writing, participating in relevant organizations compliance and ethics organizations within your industry academia

12 CONCLUDING OBSERVATIONS Developing strong, ethics-based culture is key to compliance goals and overall success of organization Keep focus sharp and ongoing. Complacency is your enemy Leaders must set the tone Frontline employees must be engaged in the effort Have a plan 23 12