Your Quick Guide To Managing Ethics & Compliance

In the last newsletter, I discussed my issues with decision-making models that include “Is it legal?” as a step – just because you think you can doesn’t mean you should. Now it’s another stalwart of ethical decision frameworks: “Is it in line with our values?”.

Which values? The ones on the website or those people observe?

Have you ever had a creepy supervisor/manager say, “Don’t do anything I wouldn’t do”, before laying out how they would do most things? No? Lucky you. I’ve had a couple, including one gent who spent his days sitting in a walk-in refrigerator reading soft-core pornography. Surprisingly, he’s not become a politician yet.

I have no idea what the values were for those organisations, as I was focused on escaping. LinkedIn is the business class lounge of the working world. We gripe about the slightly curled sandwiches and lack of ice before boarding and eating first, imbibing most, and reclining a bit bloated and wondering why sleep is so elusive. There aren’t many farm labourers, factory workers, or BPO temps posting about life in the back of the bus. If you’re asking people to consider your values, be mindful that their immediate team and managers dictate the experienced reality of corporate values for many employees. Board-level aspirational statements might be very distant.

I like the idea of honest values, but it is helpful to explain how they fall over when they’re performative, poorly defined, contradictory, and theoretical (not measured). Perhaps if we understand how not to do it, it will become easier to create decision-making systems where values mean something.

Performative values

The corporate values bingo below is an aggregation of the most recurring amongst the bid corporations; Fortune 500 and alike (original post here: https://bit.ly/3PnjGMd). I like to call this Purpass©.

Corporate values bingo

When you distil aspirational words, you might argue that this homogeneity was always likely. How many different ways can you express a value or invention, or creativity? It’s a fair point. But what makes most people raise a smirk 😏 is not the words but how hollow they sound when contrasted with contradictory actions.

What we say and what we do

I also posted about that (https://bit.ly/3N7JslI; image above), contrasting value statements against headlines of repeated corporate misdeeds. To understand the dissonance, we must consider where these words come from. Are they voted for by the employee (or heaven-forbid broader stakeholder) population? Not typically, although I know Nick Gallo at Compliance Line and others have done this successfully. Most values are a blend of:

  • Inherited words from a different era.
  • Senior leaders’ honest, aspirational, or contrived perceptions.
  • Someone in marketing or comms.
  • The flattery of a PR firm with little appetite for a pissed-off client.

You may point to exceptions, where charismatic leaders (often in pioneering and, therefore, immature sectors) define a vision that underlings follow religiously. Fair enough, but wait until crises and redundancies come; that’s a test of values. For most organisations, using stale, disjointed, or performative value words and then asking people to use those constructs to make sound ethical decisions is foolhardy.

CTA (call to action): check if your value words reflect risk and operational realities. If not, crowdsource more honest and constructive ones.

Values without definition

The words above, without further explanation, can be dangerous. Let’s use a few hypothetical to make the point:

  1. Client-focused: Your salespeople lavish entertainment and gifts on critical clients, leading to a knock on the door from anti-bribery regulators.
  2. Solutions: Safety trials are moving slowly owing to what you feel are overly cautious regulators in established Country X, so you move testing to a country with lax testing requirements.
  3. Innovation: Your brilliant tech folks can develop an algorithm that tells people which of their friends and family like them (by measuring post engagement).
  4. Value: Costs are spiralling in inflation-prone Market A, so you make everyone redundant and move operations to human-trafficking-prone Market B.
  5. Accountability: When all the decisions above go pear-shaped, you fire someone in middle management.

I have learned – the hard way – especially with my daughter, that pithy messages with established constructs and intentions (locked in my head) travel poorly as instructions. Talking of my daughter, we did our family Code a while back (one extract below). The lines under each word provided the framework to hold each other accountable.

Family values - kindness, explained

CTA: Bring words to life with clear instructions and some examples.

Values are not created equal

If you have five values, are they all equal? Come on, be honest! We can all see anyway. Companies who list inclusion, diversity, and fairness, but none of that is reflected in senior leadership roles, aren’t fooling anyone. What do “learning” and “innovation” mean if learning and innovation are not supported by training and professional development frameworks? Don’t get me started on “fun” and “honesty”. If you have a culture where views are expressed freely and openly, that’s not always a good thing. In some cultures, there is a subtlety to filtering thoughts up and down organisations not to shame or embarrass people; we don’t all enjoy confrontation. Additionally, just because you have your truth doesn’t mean everyone else has to respect it.

Again, spelling out how the values are lived and demonstrated will help. But so will being honest about your cornerstone ethical value(s). Usually, it’s one word; which one? If you’re using these values to make decision-making frameworks, maybe pull out the word that works best in that context.

CTA: Not all values help make ethical decisions; bring out the one (maximum two) that might help and spell out the intended expression of that value(s).

Values without consequences or rewards

They become even more ethereal and superfluous if your values don’t link to KPIs and disciplinary measures. I know a lot of firms have values keyed into HR management systems, but the metrics of measurement are pretty rubbish (aren’t they?). Employees need to know that (not) living the values has tangible consequences.

Having a manager judge whether Derek from Finance acted with integrity this year is unlikely to push the needle. There is hope if your values are defined and reflective of organisational realities. But if we are not measured by a cross-section of our stakeholders, the results will be skewed (best case) or performative (scored high by managers scared of conflict).

If that sounds like a lot of work, not really. You can create a survey with simple stars voting systems (⭐️ to ⭐️⭐️⭐️⭐️⭐️) that take a maximum of 2mins to complete and randomly assign them to five people at different levels within the team (and other proximate groups).

CTA: Living values must have benefits and downsides if they’re to matter to many employees.

Valuable values

I started saying I am not anti-values, and you may be querying that assertion! I think values are a fantastic bedrock for organisational (and therefore ethical) culture – they need to be realistic, honest, measurable, and clearly defined though.

Getting values right will help with ethical decision-making frameworks. But getting them wrong will confuse (best case), piss people off (worst case), or just be ignored (most likely).

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Your Quick Guide To Managing Ethics & Compliance

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