Eight Easy Steps to Ethics Success
It does this through an eight step ethics and compliance program, which is focused on helping employees choose to do the right thing in everything they do.
Any company can adopt these eight steps to begin or improve its comprehensive ethics program.
The first step is setting up an ethics office, which consists of the executive sponsor of the ethics program, the vice president, internal audit and chief ethics officer and the ethics and compliance programs administrator. This office is responsible full-time for the structure, content and administration of the ethics program across the entire organization, and for keeping it aligned with — and sometimes leading —industry best practices.
The next step is to orient all employees to the code of ethics and standards of business conduct. This begins with the company’s vision, mission, values and cultural insights, which in turn provides a guide for doing what is right. Supplemental orientation materials address five aspects of the workplace: environment, information recording and reporting, protecting resources, conflicts of interest and community relations.
The firm wants employees in every aspect of the business to be fully armed to do what is right and to know what to do when in doubt. The materials stress that these standards apply not only to relationships with each other, but also with customers, subcontractors, independent contractors, vendors and consultants.
Words alone are not enough. All new employees attend an initial Ethics 101 course, followed by annual refreshers. To keep these courses fun and engaging for employees, we are now using digital gaming technology and competition.
Step three is the digital compliance training, which is mandatory for all exempt and certain non-exempt employees. Using various job groupings — senior managers and executives, team leaders, supervisors and managers — ensures courses are tailored and effective. Different employee groups will have different requirements as to the frequency of training per year. This is tracked and monitored closely, using reporting tools to ensure employee-wide completion.
Next, we establish a consistent curriculum or program guide, prescribing detailed instructions and procedures in several broad areas such as: how to implement ethics orientations and refreshers (including how to use the orientation materials), how to field questions and how to have effective recordkeeping. It also provides frequently asked questions, directions for reporting and auditing the program and direct access to resources for implementing the ethics program.
The fifth step is to appoint 25 company-wide ethics officers at varying levels across all locations. These are each business and/or staff unit’s contact for employees seeking to discuss the right thing to do or simply to report a concern, and are responsible for follow-ups on all telephone, website or help line reports they receive. They also ensure a full confidential investigation when needed.
Ethics officers are typically visible leaders selected to encourage and stimulate a culture of ethical sensitivity and compliant behavior. Employees must view the officer as an objective third party, above office politics and favoritism — someone who serves as a safe haven for information, advice and issue resolution.
Step six is to conduct annual ethics audits, to ensure that an overall program is current and functioning as intended, and that employees across locations and departments are informed and in compliance. These audits examine everything from training documents to help line complaint resolutions. Random surveying and interviews from corporate subsets augment formal audits.
Step seven emphasizes a safe way for employees to raise their concerns without fear of retaliation — through an anonymous help line and website. Confidentiality is critical to the success of an ethics program. All calls are answered by a third party communications specialist who documents caller concerns or questions. They are timely forwarded to the appropriate company representative under a prioritization system that is regularly reviewed and refined to ensure all calls are quickly and properly addressed.
The final step of the program is to establish a separate governing ethics committee, which reviews and oversees all ethics activities. It consists of leaders who have a real stake in a successful program, such as the general counsel, the CFO, the senior vice president, human resources, the vice president, internal audit and the chief ethics officer.
Regardless of a company’s history, in this day and age, without a firm commitment and formalized program to foster ethics, success will be hard-fought. These eight steps have enabled Day & Zimmermann to succeed through tough economic cycles, periods of supreme growth and even through wide-spread diversification. They truly have been the backbone of its success. In 2012, the firm received an A ranking by Transparency International in its Defense Companies Anti-Corruption Index.
Jamal Ahmed is the vice president of internal audit at Day & Zimmermann, a construction, engineering, staffing and defense contractor. The opinions expressed are his own.