(Part 2 of an ongoing series)
As a business ethics motivational speaker, business ethics consultant and ethics book author, I was naturally interested in what the NASDAQ stock exchange felt the 5 key components of creating an ethics program for a new era might be. While their summary was written pre-pandemic (April 2019), it is surprisingly inciteful. To review the stock exchange’s take on the matter:
- Establish clear accountability for ethical culture as a management function
- Evaluate your employee-facing compliance policies so they enable rather than inhibit ethical culture
- Include ethical behaviors in promotion criteria.
- Ensure executives and managers have the skills to build and maintain an ethical culture
- Prepare managers to identify and respond to employee ethics and compliance concerns
Creating an ethics program for a new era. 5 key components
While all five points are important and vital, as a business ethics speaker, business ethics consultant and book author, I want to explore the second point, the evaluation of employee facing compliance policies as a key issue for now – and in the future. Why?
All too often, as the summary suggests, “Overly detailed and technical policies can undercut an ethical culture. This is especially true when responsibility for compliance falls on individual “line” employees and managers.”
In relating business ethics and corporate social responsibility to employees and managers, both line employees and their managers are frequently left in the dark. Often, the organization will include esoteric or feel-good messaging in their correspondence, online presence or, if publicly-traded, their annual reports. For example, “We believe that every employee, empowered with ethical values, will create change and empower a better world.”
And, if you like that kind of stuff, such statements make everyone feel good. The problem becomes that when one of those empowered, ethically driven employees needs to actually determine what a specific policy might be, they might go to an employee manual of some type and encounter a 10-page treatise written by the Harvard Law School! Invariably it is impossible for anyone outside of compliance to understand the policies.
As a business ethics consultant, I have been asked to sit-in and observe legal teams construct ethics policies for upper management. I speak on business ethics as my profession and my passion and frankly, some of the discussions on policy are so obtuse and impossible to navigate that no line employee or manager could ever hope to be perfect.
Complex doesn’t mean better
Once the ethical policies are firmly established, compliance has the responsibility to create a working group with and for “regular” employees.
I need to emphasize “regular” doesn’t mean dull or unwise. An employee capable of opening a new account, assisting in a surgery or operating a complex piece of equipment most certainly has the ability to understand ethical policy.
Straightforward policy must also be posted on internal networks and in manuals for quick reference and interpretation. The language should be suitable for quick reference and again, in plain-spoken language.
The important message here is that if the organization is creating an ethics program for a new era, whether 5 or more key components, the ethics program must be readily translatable and relatable to everyone.
To bring forth a complex ethical policy that leaves line employees and managers in doubt, is – in and of itself – unethical.
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