The ethics and compliance program should not primarily be designed for the benefit of the company. Try telling that to your C-suite and see how much resource support you get.
However, consider the ethics and compliance program primarily be designed for the benefit of employees, and your company might find the payoff to be greater than that of a program that puts the business first.
This notion is at the core of Adam Balfour’s book, “Ethics & Compliance for Humans.” Balfour, vice president and general counsel for corporate compliance at Bridgestone Americas, writes not only of his experiences learned on the job but also his personal perspectives as someone who, in his words, is “on a mission to make ethics and compliance more relatable and relevant for his fellow human beings.”
“What I have learned over the years is that an ethics and compliance program is not about complying with the law; it’s about getting your organization’s employees and other human beings to act in a way that ensures the organization complies with the law,” writes Balfour.
Early in his book, Balfour recounts the impact a speaker discussing brand management had on his view of ethics and compliance. By thinking of compliance from a brand perspective, you can ask yourself whether the perception employees have of the brand is favorable.
Doing things by the letter of the law might impress your regulators. But a program that puts the human experience of people first? That’s something individuals are quicker to rally behind.
“[T]here are many other stakeholders—including your employees and those who rely on their income—who also have a vested interest in your organization’s ethics and compliance program,” writes Balfour. “The best way to show care for your organization’s employees is by making sure they aren’t at risk of losing their jobs as a result of a massive compliance scandal.”
Other ideas expressed by Balfour in his book that stood out to me included:
- How “speak-up culture” is a backwards concept—speaking up is the outcome of culture. Leaders, managers, and supervisors should be the ones speaking up on ethics and compliance so that the pressure is not being placed unduly on the employees.
- The “training and communication” mindset should be changed to one of “learning and engagement” to better emphasize the intended impact of the process. “A key mantra to keep in mind is that not all training results in learning and not all learning will look like training,” writes Balfour.
- A direct manager’s less-than-perfect delivery of an ethics and compliance-minded message will almost assuredly have more impact than any finely crafted policy or computer message.
- Ethics and compliance policies must reflect different people in the organization have different roles, meaning breaking things down to ensure the correct message is being delivered to the correct audience is often worth the effort.
- Support for the rise of the chief purpose officer among the C-suite ranks could be a difference-maker for ensuring companies stay true to their stated goals of integrity.
These topics only scratch the surface of the interesting views shared in “Ethics & Compliance for Humans.” Despite my engaging with Balfour as a Compliance Week Advisory Board member, a speaker at CW events, and a must-follow on LinkedIn for his Sunday morning compliance tips, I felt I came away from his book with a better understanding of the potential ethics and compliance programs have to influence better human behavior.
That impact can extend beyond what’s good for the company to what’s good for society. That’s a win-win scenario we can all get behind.
“The ethics and compliance function is about humans—and helping humans use their ability and potential for good,” Balfour writes. “Ethics and compliance ultimately can help us to be humans with humanity in our workplaces, communities, and the world at large.”