Your Quick Guide To Managing Ethics & Compliance

Santa, 6-year-old logic, and bribery training

“Santa won’t fit.”

Our six-year-old is a creature of logic. We don’t have a chimney. We have a wood-burning stove where the flume is about the circumference of a medium-sized cooking pot. He’d been learning about Santa at school, came home, scanned the pipe leading into a furnace the size of a large microwave and proclaimed, “No, he won’t fit.”

My wife initially suggested Santa might delegate to a very slender, shapeshifting elf. This reminded me of an episode of The X-Files, where a stretchy serial killer slunk around wall cavities before eating people’s organs. I decided not to share that trip down memory lane. Luke added, “But how would the elf open the wood burner door from the inside?”

As we embarked on vagaries like, “He’s very resourceful and will find a way … his suit is fireproof … and also won’t get covered in soot,” it reminded me of work, particularly the anti-bribery and anti-corruption (ABAC) training of yesteryear.

In the 2010-2017 period (before Trump; when the FCPA was scary), I saw quite a lot of training and awareness raising that went:

😖 Bribing will land you in jail

😖 Look at all these scary prosecutions

😖 You can’t pay small bribes either

😖 But, bribery is endemic where you live

😖 Now go forth and act accordingly

It was a mess, much like our parental flailing around Santa. The logic is flawed.

For senior leaders, often distanced from frontline realities, sat in their European or North American gleaming edifices, bribery only happens in the movies (or Congress/parliament). No one they know is in jail. The training wasn’t relaying the impact in relatable terms. The story was lacking. “Well, my friend says Santa isn’t real.”

For frontline employees, you ask them not to pay small bribes that are everyday occurrences in most spheres of life – healthcare, education, transport, etc. You might also ask for high revenue growth without bungs in places where contracts are awarded corruptly. But you provide NO tactical guidance on how to resist, avoid, mitigate, transfer, or provide alternative (ethical) incentives. It’s like saying to someone, “The drinking water is unsafe,” and then asking them to live in that place without alternative forms of hydration or supporting them with purification, filtering, distillation, etc.; tricky.

I know most of us have come a long way. Still, suppose we’re tasked with communicating something logically challenging, like the dreaded “zero tolerance.” In that case, it’s no longer good enough to leave it at the why (Santa won’t give gifts to naughty kids) or what (shapeshifting, supersonic reindeer, and unending toy storage capacity). Be prepared for the how. And make that tactical!

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