A certain type of person exists in many large organizations, and compliance officers refer to them by many names: ambassadors, champions, liaisons. Regardless, the role of this person is always the same: to be the local voice of the chief ethics and compliance officer, assisting the CCO in promoting and embedding ethical values throughout the company.
Finding these people is not always easy. Cultivating them into a productive support network to help you manage compliance, even less so.
Ethics and compliance officers who have built such networks say the process starts with selecting the right candidates. “They are the folks you’d naturally seek out in the organization,” says Michael Miller, executive director of ethics and compliance at GenCorp, an aerospace and defense manufacturer. Miller rattles off a few qualities he likes to see in a good compliance liaison:
Friendly and approachable;
Respected by their peers and management;
Effective communication and listening skills;
Able to handle difficult situations; and
Comfortable with elevating issues.
The nomination process is just the first step. At GenCorp, for example, after business unit leaders nominate ethics champions, those people are vetted for “unknown issues,” such as any case history with HR or legal concerns, “so that we can say with good conscience to the rest of the company that these folks are outstanding,” says Miller, who established the company’s “Ethics Champions” program in 2013.
And, says Graham Luck, senior ethics officer for Lockheed Martin International, a good compliance officer has to be enthusiastic about what can be a hard job. “It’s fundamental to us that employees do the right thing, and sometimes this is the more difficult option for the employee—so the ethics ambassadors need to be positive and persuasive,” Luck says.
Lockheed Martin’s “Ethics Ambassadors” selection process is similar to GenCorp’s. “Resumes are reviewed and a subset of candidates is selected for interviews,” Luck says. “Candidates are then interviewed in conjunction with HR, and only the best candidates are selected.”
“Our goal was to leverage the employee’s operational experience and expertise in the business unit.”
Marilyn Bray, Ethics & Compliance Expert, DTE Energy
How many ambassadors or liaisons should you have? That varies, widely, from company to company. GenCorp, for example, has five dedicated compliance staffers and 14 U.S. locations, so clearly the team could not be everywhere at all times. The idea, Miller says, was to establish representatives in each site.
When DTE Energy first established its “Compliance Liaison” program in 2007, the decision was to appoint 36 compliance liaisons (one within each local business unit), says Marilyn Bray, an ethics and compliance officer at DTE Energy. By comparison, the far larger Lockheed Martin has 27 ambassadors in the United States, four in the Far East, and seven more in Europe. “As the international business grows, further additions are planned,” Luck says.
Other companies have even more liaisons. At Alstom, for example, roughly 300 ambassadors support the ethics and compliance team. The ambassadors come mainly from the legal, finance, and HR functions, or are Alstom country presidents. “The E&C ambassadors are all volunteers whose role is to disseminate Alstom’s culture of integrity within the group through ethics and compliance awareness sessions,” the company’s website states.
Roles and Responsibilities
“Ethics ambassadors are the local ‘eyes and ears’ for the full-time ethics officers,” Luck says. They provide an additional point of contact for those who may find a local, familiar face more approachable to raise concerns than the chief ethics officer at central HQ. “For issues that require an investigation, the ethics ambassador will transfer the case to the ethics officer,” he says.
Likewise, at DTE a compliance liaison is “a resource person for compliance-related communications and coordination of activities between the various business units and the ethics and compliance office,” Bray says. “Our goal was to leverage the employee’s operational experience and expertise in the business unit.”
At Lockheed Martin, “ethics ambassadors bring critical local and cultural knowledge to the program,” Luck says. “They help with the local implementation of corporate policies and are a key contributor to ethics employee communications.”
Alcoa launched a similar program in 2013 called the “Integrity Champion Network,” whose purpose is “to better integrate our ethics and compliance program into business operations,” the company’s website states. Senior business unit leaders nominate integrity champions, who “work to further embed and enhance a values-based culture of integrity and compliance” by working with their management teams and the ethics and compliance department.
Training is also an integral part of establishing a successful network of ethics and compliance ambassadors. “Up-front training is vital,” Luck says.
Below are excerpts from several companies’ compliance program initiatives.
Alcoa’s Integrity Champion Network
In October 2013, we launched our Integrity Champion Network to better integrate our Ethics and Compliance Program into business operations.
The champions, nominated by our senior business and resource unit leaders and confirmed by the Ethics and Compliance organization, play a key role as they work at the local level to:
Ensure that ethics and compliance are an integral part of decision making and business strategy;
Promote a culture of integrity, where employees are encouraged to speak up about ethics and compliance issues and concerns;
Raise awareness of the role that ethics and compliance plays in all aspects of Alcoa’s business; and
Serve as a trusted advisor and resource on issues related to ethics and compliance.
Partnering with their management teams and the Ethics and Compliance organization, the Integrity Champions work to further embed and enhance a values-based culture of integrity and compliance.
Alstom’s E&C Ambassadors
A community of approximately 300 E&C Ambassadors, all volunteers and coming mainly from the Legal, Finance and HR functions or being Alstom Country Presidents have been appointed to disseminate the Alstom Integrity Culture.
Their main role is to promote the culture of integrity, through E&C Awareness sessions and to be a point of contact for questions about Ethics & Compliance.
H-P’s “Ethics Champions Recognition Program”
We introduced this new quarterly recognition program to promote HP’s culture of integrity and ethical decision making, by showcasing employees or teams demonstrating ethical leadership or living HP’s values in ways that contribute to the company’s success. The program recognized five employees in 2013.
Sources: Alcoa; Alstom; H-P.
As a general matter, ethics and compliance officers say, ambassadors should be trained on their specific roles and responsibilities, as well as any relevant laws, regulations, and company policies that help drive the ethics and compliance program. “Ambassadors need to be able to provide dependable, accurate advice,” Luck says.
Lockheed Martin supports its training with an Ethics Ambassador Manual, which describes the role and the ethics organization and contains practical “Dos and Don’ts,” Luck says. It also describes the contact management process that ambassadors must follow to ensure consistency and contains tools and resources for the ethics ambassadors, he says.
To help ensure seamless communication, Lockheed Martin holds regular ethics ambassador meetings, which help maintain interest in the program and are “an opportunity to provide specific additional training,” he says.
“What really helped us a lot that first year was the follow-up,” Bray says. It’s important to answer phone calls, e-mails, and requests for meetings promptly, she says. “Whenever possible, we try to meet the compliance liaison at his or her operational business unit.”
GenCorp holds monthly “ethics champion calibration sessions,” Miller says. In those sessions, ethics champions are given the opportunity to discuss issues they may be observing in their business units, he says.
Ethics and compliance officers also stress the importance of recognizing ambassadors for their contributions. Hewlett-Packard, for example, launched an “Ethics Champions Recognition Program” to honor individual H-P employees or teams who demonstrate ethical leadership or live H-P’s values in ways that go beyond their roles and responsibilities.
Jacqueline Peterson, director of the ethics office and anti-corruption outreach at H-P, says employees or teams may be nominated by their peers if they make any of three contributions: face an ethical dilemma and choose the right course of action; recognize an issue and develop a process to mitigate it from happening again; or go above and beyond what’s expected in their daily responsibilities and add significant value from an ethics and compliance standpoint.
“It’s one of the highlights of our ethics and compliance program,” Peterson says. Since its establishment in 2013, H-P has recognized 14 employees to date.
DTE has a similar employee recognition program. “Many of them have said they appreciate being recognized,” Bray says.
For companies that want to establish E&C ambassador networks of their own, Bray recommends being patient and flexible with E&C ambassadors, understanding that their day-to-day responsibilities may need to take precedence over any projects you need them to complete. “It’s an added responsibility, not a primary task,” Miller says.
It’s also important to accept that building a network is a learn-as-you-go experience, Miller adds; you may have to make adjustments and tweaks along the way.