For Immediate Release:

Saturday, June 27, 2015

http://christopherbauer.com Helping You Create A Culture of Ethics, Compliance, and Accountability Wed, 25 Feb 2015 16:42:35 +0000 en-US hourly 1 http://wordpress.org/?v=3.8.8 http://christopherbauer.com/2015/02/25/three-reasons-your-ethics-code-probably-stinks-and-three-ways-to-fix-it/ http://christopherbauer.com/2015/02/25/three-reasons-your-ethics-code-probably-stinks-and-three-ways-to-fix-it/#comments Wed, 25 Feb 2015 16:35:50 +0000 http://christopherbauer.com/?p=421 Read more…]]>Without even seeing it, I’ll bet your ethics code stinks.

It’s a harsh assertion but strong odds are in my favor. Why? Because so many of the codes I’ve read – and I read a lot of them in my line of work – can be categorized into one of three impressively unhelpful types:

1. A LIST OF RULES CALLED AN ETHICS CODE – Obviously everyone needs to know the rules but let’s not confuse them with ethics! Ethics have to do with the broader underlying values and mandates the rules are there to represent. (If you want to understand this idea in more depth, just contact me. I’ll be happy to talk you through what I mean by this as well as its deep and broad implications for ethics, compliance and accountability.)

How To Fix It: Ethics are, among other things, a reflection of your organization’s values. Therefore, your ethics code also needs to reflect your values and not just the rules. Further, in the course of doing so, your code needs to be written in such a way that it will help employees know what to do when there isn’t a rule for something. Think of it this way, if your ethics code isn’t helping employees make better decisions, why even have it?

2. A RISK MANAGEMENT DOCUMENT CALLED AN ETHICS CODE – I used to see these almost exclusively in the financial sector and occasionally in healthcare. Lately, I have seen these rear their ugly heads in a much wider range of sectors. These are typically extensive documents, usually written by corporate counsel or some outside third party, in generally indecipherable ‘legalese’, and are designed to protect the organization from your inappropriate behavior. You’ll be asked to sign off on having received it as well as on your understanding of it but good luck figuring out what it actually means.

How To Fix It: Make no mistake, there are plenty of reasons to have effective risk management documents onboard. Just please don’t call them ethics codes. If your ethics code is going to actually help employees make better decisions, and it needs to, your employees had better be able to understand – clearly – what your code says and means. That can only happen if it is written in plain, clear language that is easy to digest, recall, and apply. (NOTE: If your code doesn’t allow all three of those outcomes, you aren’t done yet.)

3. A LIST OF ‘THE SIX CUSTOMARY THOU SHALT NOTS’ CALLED AN ETHICS CODE – This is, in my experience, by far the most common of the these three most useless ethics code types. Versions of his model might look and read quite differently but, strip away the surface differences, and what’s underneath is pretty much identical.

These codes are really simply a list of the six traditional ethics code ‘regulars’ and so they will tell you, in some wording or another, not to (1) lie, (2) cheat, (3) steal, (4) work outside your competence, (5) have inappropriate business relationships, or (6) bring dishonor to whomever is calling this their ethics code.

Those all sound pretty good, don’t they? But when was the last time you ran headlong into a torturous ethical dilemma and were helped by reminding yourself, “Oh yeah! I’m not supposed to lie, cheat or steal!” I’m guessing we can all easily file this type of ethics code under “Not Terribly Helpful” no matter how positive their intentions.

You’ll have to dig deeper. Really.

How To Fix It: This may be the simplest sounding fix in this article and yet it may well, in reality, be the toughest one by far. You’ll need to do the often-hard work to figure out what are the real-life issues your employees are likely to encounter and then address them both clearly and in practical terms in your code. There’s no way you’ll ever be able to anticipate all of them, of course, but that’s exactly why #1 above is so important (i.e. employees need to know what to do when there isn’t a rule or guideline for something).

Soooooo…

Does your ethics code help employees know how to consistently and appropriately apply your organization’s values to the issues confronting them in their day-to-day decision-making?

Is your ethics code written in practical, easily understood and easily applied language?

Does your ethics code help you know what to do as opposed to only telling you what not to do?

I don’t actually care how great your code currently looks or sounds. If it doesn’t pass all three of the above tests, I’m going to say you aren’t done yet; and, if changes still need to be made, get to it! After all, done right – meaning that in some way it drives all decisions – your code becomes a significant piece of your platform for both growth and sustained success. Why would you pass that up???

Need help with an ethics code ‘make-over’? No worries. Let me know and I’ll be happy to help in any way I can. That’s just one of the ways in which I help companies create and maintain cultures of ethics, compliance and accountability.

Christopher Bauer works with executives and managers who are highly invested in their employees consistently doing what they are supposed to be doing. In addition to speaking, training, consulting, and coaching, he writes on ethics, compliance and accountability for a wide range of both print and online publications. Further information on his programs as well as free subscriptions to his Weekly Ethics Thought are available at both www.ChristopherBauer.com and www.BauerEthicsSeminars.com.

]]>http://christopherbauer.com/2015/02/25/three-reasons-your-ethics-code-probably-stinks-and-three-ways-to-fix-it/feed/ 0 http://christopherbauer.com/2015/01/28/ethics-and-compliance-awareness-confessions-of-a-very-part-time-storyteller/ http://christopherbauer.com/2015/01/28/ethics-and-compliance-awareness-confessions-of-a-very-part-time-storyteller/#comments Wed, 28 Jan 2015 01:57:20 +0000 http://christopherbauer.com/?p=415 Read more…]]>I’m known, at least in part, as ‘the guy who makes ethics and compliance programs fun and funny’. It’s true – I bring a little humor to most of my programs and a lot of audience engagement to every one of them.

So maybe I shouldn’t be surprised.

But I am.

Here’s what happens several times a year.

“We’re putting together an ethics and compliance awareness program for our employees and we don’t want to bore them. What we’d like is for you to come in and tell some interesting, entertaining stories about big ethics and compliance failures. Our folks love those kinds of stories.”

Really, it’s pretty much every speaker’s dream. Those kinds of stories are fun to tell and audiences really do love them. Plus, of course, stories ‘stick’ with audiences far better than most other presentation styles.

But then it gets even better; it takes little or no prep work, it’s a great time and, for nothing more than that, I get my not-insignificant corporate fee. What’s not to love???

So I hate always having to say no.

That whole approach, as it turns out, is a really bad idea.

Here’s what I’ve learned over many years and many, many audiences:

1. The first problem with telling those wonderfully entertaining, over-the-top ethics/compliance failure stories is that a significant part of what makes them entertaining and fun is that audiences can so easily point and say, “That’s so completely stupid/immoral/illegal. I’m nothing like that.” We all revel in that.

The reality, though, is that we all carry the risk of ethics and compliance problems, even if unconsciously or unintentionally, and one of the central points of ethics and compliance awareness is to help folks see that. If all they come away with is, “Thank goodness I’m not that dumb”, the program – however well-intentioned – has completely missed the mark.

2. Unless those stories are clearly related to that specific audience in some easily and fully articulated way, they (the stories) can quickly become academic or, at best, far less meaningful. Stories have their place in ethics, compliance, and accountability programs – it’s not that I don’t use them – but I take the time to do my homework so I can be sure there’s a specific, easily-applied lesson pertinent to that specific audience in any story I tell. Or, if it really is for a brief entertaining-for-the-sake-of-being-entertaining moment, I don’t try to make it more meaningful than it actually is.

3. Another pitfall of using those over-the-top stories people love so much is that “over-the-top”, almost by definition, means that we already know good and well why the behavior in them was so inappropriate. So, as entertaining as those stories are, if there aren’t actually any teachable moments, what’s the point?

If you really just want to entertain folks, bring in a juggler or a clown. They will be just as memorable – maybe more – and no one will risk being stressed out realizing that, in the end, you and your speaker actually failed to raise much new awareness about ethics, compliance, and accountability. (Not trying to be harsh here – just trying to drive home my point…)

4. If I’m going to tell stories – and, again, I actually do tell stories in many of my programs – I want them to mostly be about successes and not failures. That’s because I want audience members to walk out of there saying, “What those other folks did was a great idea. We could do that!” I want to tell stories that inspire attendees to do more great things, not just avoid being an idiot.

There’s an old saying – and I have no idea of the original source – but it says that if all you want is for an audience to leave with a warm feeling, simply have them pee on their leg. Though I wish it was otherwise, programs made up primarily or exclusively of entertaining ‘tales from the front lines’ are, IMHO, the ‘warm leg’ approach to ethics and compliance programming.

Yes it’s true that they’re very enjoyable and entertaining but when all is said and done, they’re among the empty calories of the ethics and compliance training table.

So, in the end…

Do I think that ethics and compliance training should even be entertaining? Absolutely! In fact, if it isn’t entertaining and engaging, you’ve probably lost your audience before you’re even out of the proverbial gate.

Ethics and compliance programs have a storied history of being dull as dirt; that’s exactly why the swing to entertainment-as-a-goal-in-itself came to be. By all means, make programs fun, entertaining and engaging! Just be sure that the fun and entertainment are a vehicle for serious learning and not a substitute for it.

And…

Do I think stories ought to be told in ethics and compliance training? Once again, absolutely! Just be sure that they include truly teachable moments and don’t take the place of providing substantive, practical, easily-applied ideas, tools, and resources.

And…

Bottom line? You need your employees to be aware of ethics and compliance risks as well as how to avoid falling prey to them. If your programs aren’t substantive, they won’t know any of that; if your programs aren’t engaging, they still won’t know any of that because they won’t be able to stay awake long enough to hear what you need them to. Programs can’t be either watered-down on one end of the presentation spectrum or coma-inducing on the other.

Thankfully, though, those don’t have to be your choices.

Substantive ethics, compliance and accountability programs can be both engaging and entertaining. Really. In fact, it’s not only able to be done but I think it’s essential.

So…

My hope is that you’ll bring someone in – whether it’s someone with the same skill set or, I’d love to hope, me – to do exactly what I’ve suggested here. Provide ethics and compliance awareness programming that is substantive but also entertaining and engaging. Not one or two of these but all three and at the same time. The outcomes from this are what your company truly needs and the delivery style is what your employees surely deserve.

Don’t get me wrong, being entertained is great and being the entertainer is fun. Just, please, don’t ask me to entertain instead of educating and motivating.

I’d love to – I really would. But I won’t.

]]>http://christopherbauer.com/2015/01/28/ethics-and-compliance-awareness-confessions-of-a-very-part-time-storyteller/feed/ 0 http://christopherbauer.com/2015/01/06/250000-reasons-to-up-your-ethics-compliance-and-accountability-game/ http://christopherbauer.com/2015/01/06/250000-reasons-to-up-your-ethics-compliance-and-accountability-game/#comments Tue, 06 Jan 2015 03:53:58 +0000 http://christopherbauer.com/?p=411 Read more…]]>“We’re just not that kind of company.” I hear it all the time. “That would never happen here.” “We don’t have those kinds of people.”

What is the question to which those are the all-too-frequent answers? “Are there really any significant bottom-line risks faced by a lack of attention to ethics, compliance, and accountability?” What do I mean by significant? Anywhere from several million dollars to a billion dollars plus. It seems to me that those amounts represent some pretty big money to at least most organizations…

Isn’t it interesting, though, that sometimes smaller numbers actually hit us harder – or at least more easily – than bigger ones? Maybe we can relate to them more easily. Whatever the reasons, though, it’s true.

I often ask, “Do you think it could it happen in your company that one of your employees could be accused of creating some kind of hostile work environment?”

“Well, actually that has happened to us. A couple of times, actually.”

“Uh-huh… Any chance someone could be accused of some type of discrimination on the job?”

“Well, actually, yes, I can imagine that happening.”

“Uh-huh… Were you aware that those kinds of actions are often estimated to cost an average of around $250,000 each with that figure frequently tripling or more if litigated?”

“Hmmmm, I never thought about that.”

“So, if done well, do you think that an increased focus on ethics, compliance, and accountability in your department might stop even one hostile work environment or discrimination claim over the course of the careers of everyone currently working for you?”

“Sure! Probably well more than that!”

“Do you think it would cost you $250,000 to bring someone in to help you create an improved ethics, compliance, and accountability focus in your department?”

“Geez, not even close.”

Now, I can only speak for myself, of course, but I’m pretty sure I’ve never charged a single department $250,000 to help them create a better focus on ethics, compliance, and accountability.

And here’s the thing…

That above conversation is simply based on the reasonable hypothetical that this programming would help prevent just one hostile work environment or discrimination action over the entire course of every existing employee’s career. (That’s a pretty conservative expectation it seems to me.) Not a word was said about the potentially significant reductions in fraud losses, reducing or preventing the legal fees, fines, and settlement costs from a whole world of other legally enforceable compliance problems, or the huge opportunity costs caused by reputational damage. Yet each of those potentially very significant costs will be saved by an effective focus on ethics, compliance, and accountability.

So, if you or your organization are balking at investing in having someone in to help with ethics, compliance, and accountability, maybe for now I’ll skip giving you the really big financial reasons for doing it; but how about 250,000 smaller ones instead?

]]>http://christopherbauer.com/2015/01/06/250000-reasons-to-up-your-ethics-compliance-and-accountability-game/feed/ 0 http://christopherbauer.com/2014/12/15/three-reasons-youre-accountable-for-your-empoyees-accountability/ http://christopherbauer.com/2014/12/15/three-reasons-youre-accountable-for-your-empoyees-accountability/#comments Mon, 15 Dec 2014 22:57:33 +0000 http://christopherbauer.com/?p=403 Read more…]]>

Since my business is helping organizations create and maintain cultures of ethics, compliance, and accountability, it’s no surprise that I spend a lot of time in front of managers and executives, as well as leaders-in-training. One of the concerns/complaints I hear time and time again is, “I just can’t get my employees to do what they’re supposed to. I’ve pleaded. I’ve begged. I’ve encouraged. I’ve given them incentives. Nothing seems to get them doing what, or as much, as they’re supposed to!”

Really? Really? Call me crazy, annoying, or both but I’m not buying that this is entirely – or even primarily – as much about your employees as it is about you…

Assuming that you haven’t made a completely wacko hiring choice, and I’m hoping we can make that assumption, here are three places I’d suggest you look before holding them accountable for their accountability problems:

1. How clear have you been about what’s expected? I know that sounds obvious but it’s amazing how often we all fall down on this. Because we know what we expect, we assume that it’s equally clear to others. Check it out. Really. Check it out. Can they actually repeat your expectations back to you in a way that assures you that they know what’s expected? If not, make it absolutely clear. If they can…

2. Is fulfilling your expectations actually and fully in their control? Remember, their success or failure isn’t based what you think they ought to be able to do but really, truly, what can be done. Have you asked them about barriers to their success and then really listened to their answers? It doesn’t matter if those barriers are real or perceived – they’re real to your employees and, until you help them get over, under, or around those barriers, you (and they) are stuck. (NOTE: You don’t have to dumb down your expectations to make them easy. In fact, please don’t; expect great things from your employees! However, an expectation that’s actually impossible is an impossible expectation no matter how much you wish it was otherwise.)

You’ve made sure your expectations clearly pass the ‘do-able’ test? Okay…

3. Tell me how you have incentivized them. Remember that – plain and simple – we all do what’s reinforced. You’ve already given them pats on the back? A sales incentive in their pay? A productivity award at your annual banquet? I really don’t care. If your rewards aren’t changing behavior you haven’t really been listening to your employees about what’s important to them. Every one of your employees is different and every one of your departments and divisions are different. One size does not fit all! Take the time to see what’s important to those real folks – not to some ideal you have in your mind or some employee handbook version of the ideal employee – and you’ll have the knowledge to selectively reinforce the behavior you’re looking to create or expand. (NOTE: This involves not just managerial tactics but a thoughtful and strategic approach. Among the things you’ll also need to consider is whether or not reinforcing the desired behavior risks unintended consequences you’ll go on to regret. Those unintended consequences can’t always be foreseen but you’ll never spot them in advance of you don’t take the time to at least try to imagine them.)

Is all of this difficult? Of course it is! But I promise you, it’s whole lot easier than having employees unable or unwilling to join you in creating and maintaining a culture of ethics, compliance, and accountability.

Well, okay, it’s true… simply whining about how your employees are losers is waaaaaay easier than any of this. But is that really the approach you want to be known for? No? Whew. So then, go out there and start being accountable for your employees’ accountability! The coaching, consulting and training I do has shown me that this can all be done and done well. So, if you’re still not hitting your targets, let me know. I’ll be glad to help.

]]>http://christopherbauer.com/2014/12/15/three-reasons-youre-accountable-for-your-empoyees-accountability/feed/ 0 http://christopherbauer.com/2014/12/10/three-ways-to-know-if-those-core-values-of-yours-are-really-your-core-values/ http://christopherbauer.com/2014/12/10/three-ways-to-know-if-those-core-values-of-yours-are-really-your-core-values/#comments Wed, 10 Dec 2014 16:31:48 +0000 http://christopherbauer.com/?p=401 Read more…]]>

If you’re like most people, you will assure me that you (or your company) live and work – all day and every day – based on your core values. In fact, you’re likely to tell me that doing so is is the very foundation of your and your organization’s culture of ethics, compliance, and accountability. Based on my experience, though, I’m calling B.S. and here’s why…

I spend a great deal of time talking, coaching, and consulting with individuals and organizations; most can’t tell me what their core values are and, if they can, they certainly can’t tell me with any real clarity what those values actually mean.

So, can you tell me what your core values actually mean in specific, unambiguous terms? If you can, terrific! I congratulate you and hope you’ll read the rest of this article anyway for grins and giggles. However, my experience tells me that what will more likely happen is that you will tell me – quite automatically – that you can clearly state your core values when, in fact, you actually can’t.

Here are three things I suggest you do if you want me – or anyone else – to be clear that what you’re calling your core values are actually your core values:

1. You need to be able to give specific behavioral examples of what both adhering and not adhering to your values means. Not “Well, you know, it’s kind of like when you…” types of examples but specific, concrete examples for which you and anyone else could hold you accountable. (Call me a stickler for detail but I’ll say that if you can’t tell me what your values actually mean – in very concrete, behavioral terms – you can’t possibly know whether or not you are living and working by them. It’s the equivalent of trying to enforce a policy you don’t have. Unless you can clearly tell me what your values mean, you can’t possibly tell me, or anyone else, whether or not your behavior is aligned with those values – you have no actual metric available to you.)

2. Are those values your most important, most persistent priorities? If they aren’t, they may indeed be values you hold dear but they aren’t your core values. Your core values will tell you – and anyone else paying attention to you – what always comes first if you have a decision to make. (NOTE: Your core values aren’t what you wish would come first but what actually comes first in your thinking. Of course, they can also be what you aspire to have come first but aspiration alone won’t cut it here. You have to be consciously and intentionally working on first behavioralizing and then acting based on those values or you’re simply gunning for style points.)

3. Are your values stated in such as way as to help you make better and more consistent decisions? If you can’t conceptualize your core values as a tool for better decision-making, you aren’t done yet. Otherwise, sure, they may be your values but they aren’t driving anything and, if they aren’t driving anything, your talking about them is little more than an academic exercise. (And, um, if your supposedly core values aren’t actually driving your behavior, what does that say about your values, your behavior, or both?)

In my coaching and consulting, I am pretty much relentless in getting my clients to work on the above questions. After all, if your goal is to live by your core values, you had better know what those values are and what they mean.

Whether personally or organizationally, if you want to develop a values-driven culture – and ethics, compliance, and accountability all count on that – being sure that what you’re calling your core values are, in fact, your core values is a critical piece of the process.

I hope the questions above will help you be sure that your stated core values are, in fact, your core values. In either case, if I can be helpful to you or your company in answering these questions or more effectively leveraging your answers, I hope you’ll let me know.

]]>http://christopherbauer.com/2014/12/10/three-ways-to-know-if-those-core-values-of-yours-are-really-your-core-values/feed/ 0 http://christopherbauer.com/2014/11/21/can-an-old-dog-learn-new-ethics-tricks-and-are-you-working-with-the-right-dog/ http://christopherbauer.com/2014/11/21/can-an-old-dog-learn-new-ethics-tricks-and-are-you-working-with-the-right-dog/#comments Fri, 21 Nov 2014 16:53:36 +0000 http://christopherbauer.com/?p=398 Read more…]]>

Well, it happened again. A couple of weeks ago, during a break in a three-hour ethics program, a gentleman told me, “You know, all this is well and good but I think that if you haven’t learned ethics around the dining room table as a kid or from your kindergarten or Sunday school teachers, there’s really not much you can get from ethics training. And, if you have learned it in there, you really don’t need to hear much more about it now.” Two additional things you should know… First, I hear some version of this all the time. Second, and to my horror, this individual turned out to be the ethics and compliance officer at a moderate-size company.

So, how did I respond to this ‘pushback’? The same way I do every time I hear those types of comments:

1. I really do believe that old dogs can learn new tricks. Give them a motivating reason to pay attention as well as then taking action and they’ll do it far more often than not. If they don’t, pay some more attention to how you’re trying to get them to change. My money says that your approach is more likely to need adjusting than theirs. Boring won’t work. Difficult to understand won’t work. Difficult to apply won’t work. Difficult to recall may work briefly but only for that short while until it’s forgotten. Forgetting to conspicuously model, notice, and reinforce appropriate, positive changes also won’t work.

2. I don’t know about you and your organization but my goal in providing ethics, compliance, and accountability programming isn’t for the bad guys (and gals) to have some sudden epiphany and fall to their knees in repentance. If that happens, wonderful! It’s certainly not my goal, though. My goal is always to help folks who want to do the right thing have an easier time doing it. I want them to leave the room with immediately understandable and immediately, easily applicable ideas, tools, and resources to go about doing exactly the great job with ethics, compliance, and accountability they already want to do. If in the course of doing that great job they can now more easily notice and more appropriately confront others who aren’t doing the right thing, then it seems to me that I’ve done my job as it should be done.

So, can an old dog learn new tricks? When it comes to ethics, compliance, and accountability, I certainly think so. Just be sure that you’re working with the right dogs and in the right way. Need help figuring out how to do that – or simply want someone to do it for you? Let me know! I’ll be happy to help.

]]>http://christopherbauer.com/2014/11/21/can-an-old-dog-learn-new-ethics-tricks-and-are-you-working-with-the-right-dog/feed/ 0 http://christopherbauer.com/2014/11/11/three-reasons-having-an-ethicscompliance-officer-can-be-a-truly-bad-idea/ http://christopherbauer.com/2014/11/11/three-reasons-having-an-ethicscompliance-officer-can-be-a-truly-bad-idea/#comments Tue, 11 Nov 2014 13:46:50 +0000 http://christopherbauer.com/?p=394 Read more…]]>Ethics and compliance are obviously deeply intertwined so it makes complete conceptual sense to have an ethics/compliance officer. One stop shopping. Instant and automatic integration between ethics and compliance. It’s really pretty much of a conceptual slam-dunk no-brainer part of the path to integrity and accountability.

Some things, however, are far better in theory than in practice…

In my experience, the title of ethics/compliance officer is actually troublingly misleading and here’s why:

• In most organizations requiring a compliance officer, there is already a full-time job (or two or three) in doing the compliance work alone. Since, also in most organizations, compliance is where the real gravity is to be found, these folks – no matter how terrific their intentions – quickly become defacto compliance officers with the ethics portion of the job taking a persistently minimal back seat at most.

• No matter how related ethics and compliance are, they are still different practices with different strategies and tactics needed to fulfill their respective promises. It would take far more focus and training – not to speak of time – than most folks are afforded to really be able to serve both masters well. To really do either job, one pretty much has to ‘pick a lane’ and keep their focus there; trying to do both with any reasonable level of skill is a task beyond most mere mortals. And yet, calling someone an “ethics/compliance officer” suggests that they are, in fact, responsible for equally covering both sides of this highly complicated coin.

Here’s another way to think about this one… Manufacturing and sales are also highly intertwined yet I’m guessing not many organizations have a “VP for Manufacturing and Sales.” Just because two functions are highly related – or even inter-related – doesn’t mean it is therefore sensible to combine them.

• A significant percentage of ethics/compliance officers are attorneys and, by their training, are more oriented towards the compliance side of the equation. This pre-selection frequently, in itself, skews the ethics/compliance officer’s attention towards compliance. (Before the flames start, let me be clear. This is not some subtle dig on the ethics of attorneys. I am simply saying that attorneys’ training, by its very nature, tends to be more oriented towards compliance. Add to that the above-mentioned gravity of compliance in most organizations and these folks are likely to be swimming upstream hard when it comes to attending to ethics nearly as much as to compliance.)

Want to make a solid case to both your employees and your customers that you take ethics seriously? Put someone in charge of ethics – and ethics alone – and then give them the necessary authority and resources to both investigate and intervene as needed. They will certainly need to work in concert with your compliance office. However, at that point both your compliance office and your ethics office, collectively, will be able to do their respective jobs as they actually need to be done. In fact, it wouldn’t surprise me if the proverbial whole is greater than the sum of the parts.

Will having a separate ethics and compliance officer look less efficient to some folks? No doubt and, in fact, I would say that it’s likely to look less efficient, especially when viewed solely via some spreadsheet detached from the actual demands of day-to-day ethics and compliance challenges. I would also suggest, though, that running a tight ship both on the ethics and compliance side will, in all likelihood, pay for itself many, many times over. Having one person provide both functions, however, is simply not likely to get you there.

Admittedly, maybe you’re one of the people or the one of companies who can really pull the ethics/compliance officer job off. I’ve certainly seen it happen. Often, though? No. Very no.

So, is having an ethics/compliance officer as good in the real world as in theory? You know my thoughts. I’d love to hear yours.

]]>http://christopherbauer.com/2014/11/11/three-reasons-having-an-ethicscompliance-officer-can-be-a-truly-bad-idea/feed/ 0 http://christopherbauer.com/2014/11/05/six-reasons-your-company-should-pay-less-attention-to-the-rules/ http://christopherbauer.com/2014/11/05/six-reasons-your-company-should-pay-less-attention-to-the-rules/#comments Wed, 05 Nov 2014 19:23:21 +0000 http://christopherbauer.com/?p=392 Read more…]]>Sure, everybody in your organization needs to know the rules but if you think that’s going to be enough to hold anyone accountable, I’d think again. So, maybe my point has less to do with a need to pay less attention to the rules and, instead, a need to pay a whole lot more attention to other things as well.

Of the many reasons it’s not enough to just focus on the rules, here are a few that seem to come up constantly in my work… (NOTE: Arguably, every one of these falls under the category of common sense. Yet, I see them all the time.)

• Perhaps the most obvious-sounding one and yet one that somehow still manages to get overlooked time after time after time; knowing and doing are not one and the same. You can’t simply tell people what do and expect that it ends there. They need to be encouraged and reinforced for putting the rules and expectations into action. Complain all you want that you shouldn’t have to do that but, I promise you, you have to do that.

• Not every rule is as easy to put into practice as you think. Do your employees see barriers – whether real or simply perceived – to following the rules? You can’t know that unless you ask and once you ask, you need to be prepared to help them overcome those barriers. Otherwise, any training on the rules and expectations has the potential to be of little or no actual value.

• Piggy-backing on the last one… Are you asking employees to do things that are, in fact, fully in their control? Perhaps it sounds silly but I often see folks being held accountable for things that are partially or even entirely out of their control. It doesn’t matter how many times you tell an employee they have to so something they can’t do – I promise it’s not going to happen.

• Do your employees know the actual value of the rules on which they’re trained? And by that, I mean do they know the value of following the rules in contributing to their personal success? If not, they’ll be less motivated to attend to them. Sure, we all want employees to be attentive to the rules just because they’re the rules but we also know that isn’t often enough. Without that extra motivation, it’s really just the same power struggle we so often find between parents and kids. The moment the reason to follow a rule or meet an expectation is “because I told you so”, you’ve likely already lost the battle in part or in whole. (Plus, see bullet point #1 above…)

• Knowing the rules and expectations is essential for holding employees (and ourselves) accountable. However, if we don’t also know what to do when there isn’t a rule or expectation for something, we’re up the proverbial creek. After all, as many rules and expectations as there are, there will always be waaaaay more things for which there aren’t any. Are your employees fully trained on this? They absolutely need to be. Sometimes organizations get so focused on the rules that this idea gets lost and that’s dangerous in more ways than I can count.

• Here’s a sometimes-touchy one… Do your employees feel empowered to speak up when a rule, policy or procedure really isn’t the right tool for the job? Sometimes, blindly following the rules – as we all know when we think about it – can be the worst possible choice. If ‘doing the right thing” in your organization simply means following the rules, remember that you may well be heading for serious trouble. For starters, few rules – especially when we’re talking about internal polices and procedures – are set in stone and they certainly shouldn’t be. Better to update a rule to reflect how your organization really does business than either try to enforce an unenforceable rule or tell employees “Oh, that rule isn’t really important.” Once you label a rule – any rule – as ‘unimportant’, it takes a millisecond for employees to start deciding for themselves which rules they think are important and which aren’t. That’s a problem well-worth avoiding! Secondly, from the standpoint of ethics, sometimes there are rules or expectations that really shouldn’t be followed. (But that’s entirely another discussion…)

It’s always seductive to think that teaching the rules, policies and procedures is the singular foundation for holding employees accountable. Were it only so easy…

By all means, train on the rules and set crystal-cleat expectations. You need to! Just be sure to keep in mind that, if you’re really after a culture where everyone is accountable, teaching those rules and setting those expectations are simply a starting place. Obviously they are essential. Just remember that they are equally clearly insufficient.

]]>http://christopherbauer.com/2014/11/05/six-reasons-your-company-should-pay-less-attention-to-the-rules/feed/ 0 http://christopherbauer.com/2014/10/31/two-reasons-ill-bet-your-values-statement-stinks-and-why-that-matters-so-very-much/ http://christopherbauer.com/2014/10/31/two-reasons-ill-bet-your-values-statement-stinks-and-why-that-matters-so-very-much/#comments Fri, 31 Oct 2014 01:08:39 +0000 http://christopherbauer.com/?p=388 Read more…]]>