Measuring Corporate Culture: Enhancing the Board s Understanding

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Corporate Governance Presents: Measuring Corporate Culture: Enhancing the Board s Understanding John C. Lenzi, Chief Compliance Officer, Altria Corporate Services, Altria Group, Inc. Timothy T. Lupfer, Deloitte Consulting LLP August 8, 2007

Agenda What is this amorphous thing called culture? The practical value of an ethical culture Components and what we should measure Programs Leadership Assessment of ethical climate Important findings Ethics as a competitive advantage 1

Culture Here is a good working definition: Culture is the set of enduring and underlying assumptions and norms that determine how things are actually done in the organization. 2

Ethics and Values Define Culture The values that drive behavior are the foundation of any organization s culture Ethical behavior is actually values in action All of these terms, values, ethics, and culture are frequently in the news today Why? 3

The Regulatory Environment The 2004 amendments to the Federal Sentencing Guidelines for Organizations Placed greater responsibility on Boards and top management to take active leadership to promote ethical conduct Organizations must now: Promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law. 4

Polling Question #1 Does your company have an ethics program that stresses core values and the importance of ethical behavior in business? We have a strong program We have some elements of a program We have no program Don t know / not applicable 5

Altria s Model of Ethical Culture Self Monitoring Process Ethical Leadership Audit Regime Code, Principles, Policies Rules Values Corporate Soul Source: Altria Group, Inc. 6

Why an Ethical Culture Matters An ethical culture has significant practical business aspects: Attracts and retains talent Protects the enterprise Results in better business performance Let s look at each one 7

1. Attracting Talent Source: Altria Group, Inc. Altria utilizes social research from DYG, Inc. indicating post-9/11, all generations Boomers, Gen X, and Gen Y - are now looking for a valuable life goal, and DYG sees the rise of integrity and ethics as a differentiator. Recruiting and retaining talent will now also be determined by a company s stewardship ethics. 8

2. Protecting the Enterprise From a survey by the Association of Certified Fraud Examiners: Audit activity uncovers 45.5% of cases 18.6% 11.5% 15.4% Internal audit External audit Internal controls Not bad, but note Source: Association of Certified Fraud Examiners 9

2. Protecting the Enterprise (cont d) The greatest source to uncover fraud and theft is individual tips, uncovering 46.2% of total cases: 26.3% 8.6% 6.2% 5.1% Employee tips Customer tips Anonymous tips Vendor tips Source: Association of Certified Fraud Examiners 10

Polling Question #2 What is your company s view about the connection between ethical behavior and business success? It intuitively makes sense to us A bit of a stretch; it s one of many factors in success, but not a critical one Our market competition is dog-eat-dog; ethical behavior actually inhibits good performance Don t know / not applicable 11

3. Enhancing Business Performance Numerous studies in both the US and UK have shown that companies that make values part of their business decision-making process have a strong record in achieving long-term business success. 12

Culture: Getting the Picture So, with that background, what should we be doing, and what should we be measuring? There is no single magic metric that provides a complete picture of your ethical culture. We must look at a number of different aspects: Effective Programs Effective Leadership Assessment of the current ethical climate 13

1. Effective Programs All companies should have these basic activities in place, with metrics: Communication of core ethical values Conducting and tracking training (web and live) Ability to raise issues, including anonymously Tracking, addressing, and resolving issues Conducting investigations Communicating resolution of issues as appropriate 14

2. Effective Leadership Employees take their ethical cue from the observed behavior of their leaders. Does the organization: Make character a part of the hiring process, especially for senior hires? In performance evaluations is the how as important as the what? Hold leaders to the same (or higher) standard as everyone else? Punish those who fall short in ethical behavior, in spite of revenue implications? 15

3. Assessing the Current State Altria s approach has been what gets measured, gets done Measurement includes hard and soft data Key issue areas are: View of ethical culture Senior management support View of level-ism Retaliation Pressure to violate policy or the law Observing misconduct Reporting what you saw Source: Altria Group, Inc. 16

Polling Question #3 Does your company conduct a survey to gauge the ethical climate of your organization? We conduct an extensive survey, analyze the results, and report the findings We conduct a limited approach, with some aspects of surveying the ethical culture/climate of our organization We don t survey this aspect of our organizational behavior Don t know / not applicable 17

Deloitte-Funded Research Findings Does work-life balance influence positive ethical behaviors at work? According to the findings of the 2007 Deloitte & Touche USA LLP Ethics & Workplace survey, there is a strong relationship between the two factors. The survey, conducted by Harris Interactive on behalf of Deloitte & Touche USA, also showed that the behaviors of management and direct supervisors, coupled with positive reinforcement for ethical behavior, are the top factors for promoting ethical behavior in the workforce. Source: Altria Group, Inc. 18

Altria-Funded Research Findings Groundbreaking global research on ethical culture conducted by the Compliance & Ethics Leadership Council (CELC) of the Corporate Executive Board in 2007. The research found five leading indicators of potential misconduct: Retaliatory culture and discomfort with speaking up Willingness to compromise ethics for power and control Direct manager lacks trust and respect for employees Relative commitment to one s job, manager, and company Percentage of variable compensation Source: Altria Group, Inc. 19

Altria-Funded Research Findings (cont d) CELC found that concern about retaliation was the single greatest leading indicator by far. Almost double the importance of all other factors combined. The research for this study included the US, UK, Canada, Australia, and India, and the findings appear to be applicable on a wider, global scale. Source: Altria Group, Inc. 20

Polling Question #4 How confident is your company about embedding ethical accountabilities into your performance expectations? Expectations of ethical behavior are identified for all jobs Expectations of ethical behavior are identified for critical jobs or specialized functions, but not for general positions We really haven t given much thought about ethical behavior and expectations for our job positions We don t think this is relevant to job performance Don t know / not applicable 21

Altria s Conclusions Workforce demographics are changing It s a wired, transparent world Generational views focused on values In a very dynamic environment, businesses will compete hard for the best talent Emphasize values and ethics-based corporate culture Recruit and retain with a focus on corporate ethics Ethics becomes a competitive advantage Source: Altria Group, Inc. 22

Altria s Conclusions (cont d) Building and maintaining a program that simply meets the FSG is not enough But to build a strong corporate culture today, the balance among the phases of an ethics program must shift: Reactive: correcting violations of law or company policy as they arise Proactive: a comprehensive system of policies and procedures designed to prevent or detect and correct violations of the law or company policy Transformational: a proactive program integrated into business practices and culture 23 Courtesy of: 2007 PEAC Ventures, Inc. Strategic Priority--Compliance & Ethics Solutions LLC

Time Spent Time Spent Future Implications Phase 1 Phase 2 Phase 3 CURRENT Reactive Proactive Transformational Phase 1 Phase 2 Phase 3 FUTURE Reactive Proactive Transformational Courtesy of: 2007 PEAC Ventures, Inc. Strategic Priority--Compliance & Ethics Solutions LLC 24

Revisiting the Altria Model Culture Self Monitoring Ethical Leadership Process Code, Principles, Policies Audit Regime Rules Values Corporate Soul Source: Altria Group, Inc. 25

Conclusion Remember the slogan for the Clinton campaign during the 1992 presidential election? It s the economy, stupid! Today the watchword for organizations is: It s the culture, stupid! 26

Questions & Answers

Join us September 12 th at 2 PM ET as our Corporate Governance group presents: The G in Governance, Risk, and Compliance: What s the Board s Role?

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Contact Information Timothy T. Lupfer Deloitte Consulting LLP John C. ( Jack ) Lenzi The Altria Group, Inc. tlupfer@deloitte.com John.Lenzi@ALTRIA.com

The information contained in this publication is for general purposes only and is not intended, and should not be construed, as legal, accounting, or tax advice or opinion provided by Deloitte & Touche to the reader. This material may not be applicable or suitable for, the reader s specific circumstances of needs. Therefore, the information should not be used as a substitute for consultation with professional accounting, tax, or other competent advisors. Please contact a local Deloitte & Touche professional before taking any action based upon this information.

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