Title: Implementing%20Ethics%20in%20the%20Workplace:%20Creating%20the%20Process%20(Abridged%20version)%20
1Implementing Ethics in the Workplace Creating
the Process(Abridged version) a program of the
Greater Omaha Business Ethics Consortiumat
Creighton University
Sponsored by
2The Seven Sentencing Guidelines
- 1. Having Standards
- 2. Assigned Responsibility - Adequate Resources
- 3. Due diligence in Hiring
- 4. Communications and Training
- 5. Monitoring, Auditing, Reporting
- 6. Promotion and Enforcement of Ethical Conduct
- 7. Reasonable Steps to Prevent Misconduct
3The Challenge is Doing More with Less
- 1. Have a Plan - preferably a long range plan
- 2. Have support at the Top and an Ethics Team
- 3. Get an Ethics/Compliance Committee Chartered
- 4. Put in place a Code of Conduct
- 5. Get a Helpline Set Up
- 6. Communicate to Managers/Employees
- 7. Do Some Training - E-Mail,Web,Video,
- 8. Attend Other Meetings or Training Sessions
- 9. Give Leaders Ethics Messages to Send Out
- 10. Use the Company Website Extensively
- 11. Follow in the Wake of Critical Events
- 12. Regularly Report on Numbers, Issues to Mgt.
4Every Company is Unique
- Leadership
- History
- Culture
- Policies
- Practices
- People
- Regulatory Environment
5 Gallup Organization Findings Tone at the Top
VALUES One of the Seven Demands of
Leadership
6Gallup Research Based Findings
- During nearly forty years of research and tens of
thousands of interviews, Gallup has determined
the - Seven Demands of Leadership.
- These are behaviors of individuals who are
perceived as leaders within their organizations,
communities and nations.
7WHAT GREAT LEADERS DO MOST - the most commonly
expressed demands Gallup Organization
VISIONING
7 D E M A N D S
MENTORING
BUILD A CONSTITUENCY
CHALLENGING EXPERIENCES
MAKING SENSE OF EXPERIENCES
STABILIZING VALUES
KNOWING SELF
8Allocation of Time For Creating Alignment Gallup
Organization
Typical
90-100
0-5
0-5
Drafting Redrafting Statements
Identifying Core Values
Creating Alignment
Desired
0-5
10-20
80-90
Identifying Core Values
Creating Alignment
Drafting Redrafting Statements
9Organization and Personnel
10How to Manage Organizational Ethics?
- 1. Create a formal program w/resources
-
- 2. Put someone in charge of it
- General Counsel
- HR director
- Internal auditor
11Report to
- CEO
- Board of Directors
- Committee of the Board of Directors
- Senior Executive
12Support for Managing Organizational Ethics
Programs
- Ethics and Compliance Officer Association
- http//www.theecoa.org/
13Compliance with Laws
Ethical Behavior
SWEET SPOT
Compliance and Ethics Program
14BCBSNE Compliance Organization
Board of Directors
Audit Compliance Committee
Corporate Compliance Officer (VP Level)
Compliance Department (with dedicated Staff)
Compliance Cross Functional Team Members
15Responsibilities
- Provide Guidance and Answer Questions
- Create and Assist in Creating Policy Procedure
- Develop and Deliver Training
- Foster Awareness Encourage Ethical Behaviors
- Respond to Auditors and Regulators
- Respond to Complaints (Receive/Investigate/Documen
t/Resolve) - Liaison with the Board of Directors
- Listen
- Report
- Keep Current on and Facilitate Compliance with
Laws and Regulations
16Communication Training
- Getting the right message out
17What is communicated?
Ethics Materials Mission Values Code of conduct/ethics Policies Decision methods Your culture
Ethics program Who is the Ethics Officer? How to make contact?
Senior Management Commitment to Ethics Why organizational ethics matters?
18Methods of Communication
- Evaluate current ethics communication lines
- Formal and informal
- downward, upward, and two way
- Clear, consistent, credible messages across
communication lines
19More about Methods of Communication
- Hiring Announcements
- Website
- Email
- Brochures
- Meetings Formal Informal
- Orientation sessions
- Newsletters
- Manuals
- Code Handbooks w/certifications
- Badges and Wallet Cards
- Key Fobs
20Ethics Training
- Design for individual groups
- Groups
- new recruits
- existing employees
- top management
- local management
21Ethics Training
- Live
- Computer based
- Trainers
- Certification
22Helplines/Hotlines
- Getting Started, Outsourcing, Case Management,
Operational Flow, Processes, and more - Factors and Features
23Introduction
- What is a helpline/hotline and what do you need
to do to establish one? - Why set up a helpline/hotline?
- Who should answer the line?
- How does a helpline/hotline work?
- When can you expect to fully implement a
helpline/hotline? - Free Advice vendor selection, positioning,
themes, questions
24What. A Helpline/Hotline Is and Some
Alternative Reporting Mechanisms
- Helpline. a confidential toll-free telephone
number for employees or others to report
suspected violations of law or company policy and
to answer policy questions - Hotline focuses on the reporting of suspected
violations and emergencies - Consider departmental needs/requirements (Safety,
EEO, Audit, Environmental, HR) - Evolution of reporting channels
- From post office boxes
- To confidential faxes
- To voice mailboxes
- To confidential e-mails
- To web-based reporting systems
25What . You Need to Establish a Helpline
- Senior Management Support and some Money
- Understandable Guidelines for using the Helpline
that Reflect your Organizational Values and
Policies - Multi-function support (Communications, HR, IT,
Law, EEO, - Operating, Audit, etc.)
- Designated Support Personnel
- Accountability and follow-up
- Communications and Employee Awareness
26Union Pacifics Values Line
- Established in 1994 and is outsourced
(third-party service) - Covers 55,000 employees
- Is a business conduct report line
- Does not primarily support Safety, Emergencies,
Environmental, Payroll or HR services (internal
lines) - Supports EEO, Audit, Policy and Employee
Relations reporting
27Why.Set up a Helpline or Hotline?
- Understand the objectives
- Increased emphasis on organizational ethics and
compliance carrot and stick incentives - Establish formal monitoring, auditing and
reporting systems - Provide anonymous channel for reporting suspected
violations (which may otherwise be unreported) - Raise awareness of commitment to ethical conduct
- Establish a proven, effective tool for protecting
company
28Why Set up a Helpline or Hotline? Legal and
Regulatory Requirements
- Federal Sentencing guidelines One of seven
steps in an effective ethics and compliance
program - SEC implementing rules
- New York Stock Exchange proposed listing
requirements - Sarbanes-Oxley Act (enacted 2002)
- Sections 301 and 806
29Who . should answer the line?Decision Process
- External
- 24/7/365
- Anonymity
- Multilingual
- Perceived confidentiality
- Vendor Features
- Internal
- Staffing/budget
- Time constraints
- Employee trust
- Knowledge of Policies
- Translation services?
- Training/Turnover
- Software
30Who?.Analyzing Vendors
- Vendor Selection Process
- Talk with people who have lines
- Visit Vendor Websites
- Review intake process/procedures
- Request proposals, review best practices
- Include your IT department
- Perhaps absorb existing call system(s)
- Consider hidden costs, extra reporting
31How. Does a report line work?
- - Call is placed to the UP Values Line
- designated toll-free number (800-998-2000) OR
shared toll-free number - Helpline personnel records information according
to general protocol or your specific design (EEO,
FMLA, etc.) - Classifications, information, key issues
- Case is reported to you and/or others via e-mail
or web links - Case management data is summarized each month or
through ad hoc reports
32Operational Key Points
- Spread Out the Work
- Expect 1-2 of Employees to call/yr
- Who Calls the Line?
- Types of Calls, Categories
- Anonymous versus Identified (20/80)
- Sufficient Investigation Resources
- No Retaliation for good faith reporting
- Confidentiality to extent possible
- Follow up is essential
33(No Transcript)
34Questions?
- Cost 1,500 to 30,000 per year your time
- Reports see handouts
- Vendors The Network, EthicsPoint, Lighthouse,
- Allegiance, and many more.
- See handouts of hotline best practices
- Helping to maintain a culture of integrity
35Enforcement
- Ensuring Observance
- Putting into practice
- Making it happen
36Enforcement
- Reality Codes and rules without enforcement and
adherence are useless. - Question How do we ensure compliance with legal
rules and corporate policies?
37Why should you enforce?
- You have Two Choices
- Corporate Enforcement
- Government Enforcement
- The best enforcement is self-enforcement!
- Better your company do it than the EEO, SEC, IRS,
court, etc.
38Types of EnforcementThe best policy is to
prevent wrongdoing
- Getting Compliance (preventative)
- Training and Education (I didnt know)
- Review Audit for compliance and quality
- Incentives compensation and recognition
- Model Leadership talks, and walks the talk
- Punishment (responsive)
- Clear Sanctions in place
- Ethics Committee (method in place)
- Someone with oversight responsibility
39Implementing Enforcement
- Consistency is Important across Firm
- Cross-check from HR for termination issues
- Codified Policy is helpful
- Yet, Flexibility is important also
- Realize Firing is sometimes correct action for
sake of firm. - Unions usually have process/expectations
40Correcting Problems
- Sentencing Guidelines also require that you have
a method of remedying ethical problem areas in
your corporate culture - Examples
- Ethics committees
- Ombudsman
- Ethics Officer
- Stated Corporate Policy On Correction Procedure
41The Seven Sentencing Guidelines
- 1. Having Standards
- 2. Assigned Responsibility - Adequate Resources
- 3. Due diligence in Hiring
- 4. Communications and Training
- 5. Monitoring, Auditing, Reporting
- 6. Promotion and Enforcement of Ethical Conduct
- 7. Reasonable Steps to Prevent Misconduct
42Wrap Up Discussion