An Ethical Culture: Own it, Live it, Lead it

By Sandra Evers-Manly
Anyone involved in ethics and compliance within the defense industry should know that to be truly effective, a corporate ethics program requires more than a “check the box” approach. The challenge is to develop a vibrant program that resonates with employees in a manner that causes them to take true ownership of ethics within their area of responsibility. 

Over the years we, along with peer companies, and often in collaboration with the National Defense Industrial Association and the Defense Industry Initiative (DII), have shared best practices within industry in the interests of men and women in uniform.

Northrop Grumman has always endeavored to meet the requirements of applicable laws, but it has resolved to take the culture beyond that by making its ethics program more robust, proactive and holistic. In 2007, it decided to establish a direct reporting relationship to both the CEO and the board of directors. This led to the formation of an office of corporate responsibility, which not only oversees the traditional ethics and compliance functions, but also diversity and inclusion, Equal Employment Opportunity compliance, workplace accommodations, an employee assistance program, corporate citizenship and the Northrop Grumman Foundation.
This new structure helps ensure that the heart of our program is about establishing the right culture and good corporate citizenship. The right culture not only fosters ethical behavior, it also extends beyond traditional ethics and compliance. This more holistic integration has greatly contributed to the continued success of the current program.

Openly sharing best practices among all defense contractors has allowed the company to discover and apply new ways to strengthen programs and otherwise achieve effectiveness. Two key takeaways from our membership in DII are the importance of values-based ethics programs and the concept of “tone at the top.” The leadership team strives to put ethics at the forefront whether speaking to employees, industry and government leaders, or making decisions about what is best for the company.  

As important as “tone at the top” is critically important, but so too is the challenge of reaching out to all employees, to include knowing and understanding the “mood in the middle” and the “buzz at the bottom.” The ethics program is greatly enhanced by the business conduct officer network of 120 dedicated employees, who closely monitor the “middle mood” and “bottom buzz.” We also maintain an OpenLine system administered by a third party service provider to facilitate 24/7 reporting, thereby empowering all employees, including those who otherwise may not feel comfortable reporting potential ethics violations.

We also endeavor to invigorate and thereby maintain a vibrant ethical culture by periodically rebranding the ethics program to keep it fresh in the minds of the employees. In 2015, Northrop Grumman unveiled “Ethics: Own it, Live it, Lead it.” How does it work?

Own it: We own ethical culture not only by knowing the rules, regulations, policies and procedures to perform our jobs, but also by establishing the right environment and creating an organization of trust. Employees, at all levels must actively seek to own and establish an ethical culture. Company values provide the foundation for everyone to take that ownership.

Live it: We endeavor to live high ethical standards in accordance with the values the company holds dearly, to include standards of business conduct and other established rules. Each of us also seeks to make sure the Northrop Grumman values are central to every decision and action we take. The ethics program is there to spell out and help us better understand what that means or looks like, and otherwise provide guidance for those who are unsure about how to act.

Lead it: Leading ethical behavior must take place at every level. We encourage open, honest communication and an environment where we can challenge one another, and contribute to an inclusive culture where all questions, ideas, and concerns of any nature are openly shared and welcome.

Nor is a vice president or manager title in front of a name required in order for an employee to be an effective leader. Everyone should be encouraged to “lead from where you are.” An ethics award, “The High Road,” established in 2012, spotlights employees who show ethical leadership from wherever they sit in the company.

Any ethics program that succeeds in evolving in all the right ways beyond the basic minimum requirements must also be open to change, whether that be through new campaigns, slogans, logos and themes or through organizational re-alignments. The company has a “best in class” ethics program, but that means little if employees aren’t well-served by the culture, and by leaders who cultivate trust, initiatives, training, business conduct officers and foundational policies. By doing what is best for the workforce, and letting employees know they are respected, valued and “heard,” when it comes to establishing a culture of ethical best practices, they become a force multiplier.

They must always feel free to challenge others whenever they have questions, to feel included in their organizations and know they can bring their authentic selves to work each and every day. In order to see ethics and integrity throughout an organization, it must be owned, lived and led by everyone.

While Northrop Grumman knows that maintaining constant vigilance is a must, it is very proud every day to witness men and women owning, living and leading the way in choosing what is right over what may sometimes appear to be more expedient.

Sandra Evers-Manly serves as Northrop Grumman’s vice president global corporate responsibility and president of the Northrop Grumman Foundation.

Topics: Defense Contracting, Defense Contracting

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