Your Quick Guide To Managing Ethics & Compliance

The Ethical Excuses Bingo, crowdsourced here 3-4 years ago, was a turning point. I’d long had a hunch – borne from anecdotal data – that building endless controls wasn’t the solution to reducing integrity risks. Data, including that from the Association of Certified Fraud Examiners (ACFE)‘s Report to the Nations (2021), suggested control failures were the cause of fraud in 1/3 of instances. But, beyond that, it’s been hard to prove the thesis.

So I stopped. Instead, focusing on how we might change the narrative of these excuses.

Ethical Excuses Bingo

Bootstrapping Ethics, beginnings

I started the book in September 2021, and much of the first chapter focused on the importance of values. Organisations with strong values fare better on the integrity risk seas. Broadly, values are the bedrock for sound cultures. They’re like the branches where we can hang rules and other requirements. Values can also be the guardrails around decision-making.

Thank you for the support and photo

Schools get this principle (if not the execution).

When the No. 1 child gets points for goodery, the citation is tied to one of the school values – we get around three of these emails a day. We also get a form when No. 2 gets sin-binned for another violation (🙄). On this form, the teacher writes the school value he failed to uphold, and then an amazing sequence of questions:

  • Q: What did you do wrong?
  • A: Hit X.
  • Q: How do you think X felt?
  • A: Sad.
  • Q: How do you now feel?
  • A: Upset.
  • Q: Why do you feel this?
  • A: Because I’m sat here with you instead of being at play time.
  • Q: What will you do to make it right?
  • A: Say sorry to X, and never do it again.

Two days later, it happens again.

When we ask No. 1 about her many citations, she can barely remember them, let alone the value she demonstrated. Both kids know the school’s values. They’ve been drilled on them. But they struggle to understand their real-world application. What’s not working here?

De-valued

In the integrity culture surveys we run, a common question is a variation of “I am incentivised to behave ethically.” The responses vary depending on the organisation. But the free text additions are revealing, for instance:

  • I don’t think I should be incentivised.
  • I got thanks from [Compliance Officer] when I followed the process … that felt like an incentive to do so next time
  • I don’t believe I should be incentivised to behave ethically. I should behave ethically regardless.
  • Why should you need to be?

Rewarding people for doing what they’re meant to is tricky. No. 1’s school is sincere in its desire to build a very inclusive culture, but the potency is lost when praise is given away like candy during Halloween. Directing praise at people going beyond what is normal, that’s different.

The values are also hollowed out when disciplinary processes are weak. No. 1 was bullied last year. She escalated to a teacher, and after a brief pause, normal service resumed. As her parents, we’re trying to arm her with sensible tools to respond, but she explained that if she “retaliates” (verbally), she may also get in trouble. This “keep turning the other cheek” policy is bullshit. That’s not a value; that’s setting someone up to tolerate abuse.

The lesson: Your values are rendered valueless when violations go unpunished.

Values in a void

In No. 2’s case, he’s the youngest (almost the smallest) in his year. His outbursts generally follow his being shoved down the size hierarchy and pecking order (e.g., bigger kids picking the best toys). I’m not condoning, but expecting a sober analysis of his behaviour without acknowledging context seems unwise. Yes, he MUST improve his reactivity, but the worksheet does not help when it ignores the why. The ethical excuses in the bingo aren’t justifiable, but they are helpful if we’re to get to improved outcomes. Context is key.

The bingo excuses demonstrate that many excuses relate not to (direct) self-gratification or self-enrichment, but a variant of “I was doing it for you.”

That’s why, in these surveys, we might ask questions like:

Responses from a recent survey in an organisation where “deal-closing” is the KPI of note

Lesson: If values aren’t tied to realistic incentives and strategies, burn them. You’re wasting everyone’s time.

Unrealistic values

Values must match your environment. I’m not talking about those cringey, “save the world,” values beloved by the most sustainability-impaired organisations. I’m more worried about values conceived in a separate universe from the one employees inhabit. I’m sure you can all recall an instance in retail or travel where a member of the public has behaved horrendously. Do you uphold values if your employer is indifferent to your daily reality?

One of my first jobs was at an events company, providing catering at a major sports event. I was to carry boxes of wine and beer from a basement to the floor where the executive boxes were. Meanwhile, “pretty girls” were sent behind the raucous doors to serve. Some of them told me about the appalling behaviour inside, including all the groping you’d imagine in a 1990s sports venue, wine thrown on their tops/blouses, and rank comments. I raised this with a manager and offered to go in instead, full of bravado and hoping to initiate a fight. The manager told me to return to my boxes and did nothing to protect the female employees. I wrote a letter to HQ after this, and another disaster event. To their credit, they replied. But nothing changed.

The point: Values must be demonstrated externally, not just internally. Standing up to bell-ends CAN be good for business (let alone morale).

Values 2.0

Broadly, values are easier for people to build upon. Better them than a codified Magna Carta of does and don’ts. But, to work, they must:

  1. Be aspirational but attainable (don’t patronise people by lauding basic common decency).
  2. Have teeth – failing to follow MUST matter.
  3. Be in sync with strategy and incentives.
  4. Be upheld on the frontlines, where your employees meet the world.

What do you think about values?

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Your Quick Guide To Managing Ethics & Compliance

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