Implementing Ethics in the Workplace: Creating the Process a ...

Implementing Ethics in the Workplace: Creating the Process a ...

Implementing Ethics in the Workplace: Creating the Process (Abridged version) a program of the Greater Omaha Business Ethics Consortium at Creighton University Sponsored by The Seven Sentencing Guidelines 1. Having Standards 2. Assigned Responsibility - Adequate Resources 3. Due diligence in Hiring 4. Communications and Training 5. Monitoring, Auditing, Reporting

6. Promotion and Enforcement of Ethical Conduct 7. Reasonable Steps to Prevent Misconduct The Challenge is Doing More with Less 1. Have a Plan - preferably a long range plan 2. Have support at the Top and an Ethics Team 3. Get an Ethics/Compliance Committee Chartered 4. Put in place a Code of Conduct 5. Get a Helpline Set Up 6. Communicate to Managers/Employees 7. Do Some Training - E-Mail,Web,Video, 8. Attend Other Meetings or Training Sessions 9. Give Leaders Ethics Messages to Send Out 10. Use the Company Website Extensively 11. Follow in the Wake of Critical Events

12. Regularly Report on Numbers, Issues to Mgt. Every Company is Unique Leadership History Culture Policies Practices People Regulatory Environment Gallup Organization Findings Tone at the Top VALUES One of the

Seven Demands of Leadership Gallup Research Based Findings During nearly forty years of research and tens of thousands of interviews, Gallup has determined the Seven Demands of Leadership. These are behaviors of individuals who are perceived as leaders within their organizations, communities and nations. GOBEC WHAT GREAT LEADERS DO MOST - the most commonly expressed demands


STABILIZING VALUES KNOWING SELF GOBEC Allocation of Time For Creating Alignment Gallup Organization Typical 0-5% 90-100% 0-5%

Identifying Core Values Drafting & Redrafting Statements Creating Alignment Desired 10-20% Identifying Core Values 0-5%

Drafting & Redrafting Statement s GOBEC 80-90% Creating Alignment Organization and Personnel How to Manage Organizational Ethics? 1. Create a formal program w/resources 2. Put someone in charge of it

General Counsel HR director Internal auditor GOBEC Report to CEO Board of Directors Committee of the Board of Directors Senior Executive

GOBEC Support for Managing Organizational Ethics Programs Ethics and Compliance Officer Association GOBEC Compliance with Laws SWEET SPOT

Compliance and Ethics Program Ethical Behavior BCBSNE Compliance Organization Board of Directors Audit & Compliance Committee Corporate Compliance Officer (VP Level) Compliance Department (with dedicated Staff) Compliance Cross Functional Team Members GOBEC Responsibilities 1.

Provide Guidance and Answer Questions Create and Assist in Creating Policy & Procedure Develop and Deliver Training Foster Awareness & Encourage Ethical Behaviors 2. Respond to Auditors and Regulators

3. Respond to Complaints (Receive/Investigate/Document/Resolve) 4. Liaison with the Board of Directors 5. Listen

Report Keep Current on and Facilitate Compliance with Laws and Regulations GOBEC Communication & Training Getting the right message out What is communicated? Ethics Materials: Mission Values Code of conduct/ethics Policies

Decision methods Your culture Ethics program: Who is the Ethics Officer? How to make contact? Senior Management Commitment to Ethics: Why organizational ethics matters? GOBEC Methods of Communication

Evaluate current ethics communication lines Formal and informal downward, upward, and two way Clear, consistent, credible messages across communication lines GOBEC More about Methods of Communication

Hiring Announcements Website Email Brochures Meetings Formal & Informal Orientation sessions Newsletters Manuals Code Handbooks w/certifications Badges and Wallet Cards

Key Fobs GOBEC Ethics Training Design for individual groups Groups: new recruits existing employees top management local management GOBEC Ethics Training Live Computer based

Trainers Certification GOBEC Helplines/Hotlines Getting Started, Outsourcing, Case Management, Operational Flow, Processes, and more Factors and Features Introduction What is a helpline/hotline and what do you need to do to establish one? Why set up a helpline/hotline? Who should answer the line? How does a helpline/hotline work? When can you expect to fully implement a

helpline/hotline? Free Advice vendor selection, positioning, themes, questions GOBEC What. A Helpline/Hotline Is and Some Alternative Reporting Mechanisms Helpline. a confidential toll-free telephone number for employees or others to report suspected violations of law or company policy and to answer policy questions Hotline focuses on the reporting of suspected violations and emergencies Consider departmental needs/requirements (Safety, EEO, Audit, Environmental, HR) Evolution of reporting channels

From post office boxes To confidential faxes To voice mailboxes To confidential e-mails To web-based reporting systems GOBEC What . You Need to Establish a Helpline

Senior Management Support and some Money Understandable Guidelines for using the Helpline that Reflect your Organizational Values and Policies Multi-function support (Communications, HR, IT, Law, EEO, Operating, Audit, etc.) Designated Support Personnel

Accountability and follow-up Communications and Employee Awareness GOBEC Union Pacifics Values Line Established in 1994 and is outsourced (third-party service) Covers 55,000 employees Is a business conduct report line Does not primarily support Safety, Emergencies,

Environmental, Payroll or HR services (internal lines) Supports EEO, Audit, Policy and Employee Relations reporting GOBEC Why.Set up a Helpline or Hotline? Understand the objectives Increased emphasis on organizational ethics and compliance carrot and stick incentives

Establish formal monitoring, auditing and reporting systems Provide anonymous channel for reporting suspected violations (which may otherwise be unreported) Raise awareness of commitment to ethical conduct Establish a proven, effective tool for protecting company

GOBEC Why Set up a Helpline or Hotline? Legal and Regulatory Requirements Federal Sentencing guidelines One of seven steps in an effective ethics and compliance program SEC implementing rules

New York Stock Exchange proposed listing requirements Sarbanes-Oxley Act (enacted 2002) Sections 301 and 806 GOBEC Who . should answer the line? Decision Process External

24/7/365 Anonymity Multilingual Perceived confidentiality Vendor Features Internal

Staffing/budget Time constraints Employee trust Knowledge of Policies Translation services? Training/Turnover Software GOBEC Who?.Analyzing Vendors Vendor Selection Process Talk with people who have lines Visit Vendor Websites Review intake process/procedures

Request proposals, review best practices Include your IT department Perhaps absorb existing call system(s) Consider hidden costs, extra reporting GOBEC How. Does a report line work? - Call is placed to the UP Values Line designated toll-free number (800-998-2000) OR shared toll-free number Helpline personnel records information according to general protocol or your specific design (EEO, FMLA, etc.) Classifications, information, key issues Case is reported to you and/or others via e-mail or web links Case management data is summarized each month or through ad hoc reports

GOBEC Operational Key Points Spread Out the Work Expect 1-2% of Employees to call/yr

Who Calls the Line? Types of Calls, Categories Anonymous versus Identified (20/80) Sufficient Investigation Resources No Retaliation for good faith reporting Confidentiality to extent possible Follow up is essential GOBEC Types of Values Line Reports Jan. 1 - Aug. 31, 2006 Theft & Drugs 1% Pay 4%

Safety 4% Supervision/Relations Discrim./Harass. Job Perf./Fitness Threats/violence 0% 3% Other Policy 1%

Smoking Union/CMS/Discipline 6% Union/CMS/Discipline Smoking 1% Supervision/Relations 66% Safety Pay Policy

11% Theft & Drugs Discrim./Harass. 3% Threats/violence Job Perf./Fitness Butch Ethington Ombudsman 402-544-2113 595 GOBEC Other

Questions? Cost $1,500 to $30,000+ per year + your time Reports see handouts Vendors The Network, EthicsPoint, Lighthouse, Allegiance, and many more. See handouts of hotline best practices

Helping to maintain a culture of integrity GOBEC Enforcement Ensuring Observance Putting into practice Making it happen Enforcement Reality: Codes and rules without enforcement and adherence are useless. Question: How do we ensure compliance with legal rules and corporate policies?

GOBEC Why should you enforce? You have Two Choices: Corporate Enforcement Government Enforcement The best enforcement is self-enforcement! Better your company do it than the EEO, SEC, IRS, court, etc. GOBEC Types of Enforcement The best policy is to prevent wrongdoing 1. Getting Compliance (preventative)

Training and Education (I didnt know) Review: Audit for compliance and quality Incentives: compensation and recognition Model: Leadership talks, and walks the talk 2. Punishment (responsive) Clear Sanctions in place Ethics Committee (method in place)

Someone with oversight responsibility GOBEC Implementing Enforcement Consistency is Important across Firm Cross-check from HR for termination issues Codified Policy is helpful Yet, Flexibility is important also Realize Firing is sometimes correct action for sake of firm. Unions usually have process/expectations GOBEC Correcting Problems Sentencing Guidelines also require that you

have a method of remedying ethical problem areas in your corporate culture Examples: Ethics committees Ombudsman Ethics Officer Stated Corporate Policy On Correction Procedure GOBEC The Seven Sentencing Guidelines 1. Having Standards

2. Assigned Responsibility - Adequate Resources 3. Due diligence in Hiring 4. Communications and Training 5. Monitoring, Auditing, Reporting 6. Promotion and Enforcement of Ethical Conduct 7. Reasonable Steps to Prevent Misconduct Wrap Up Discussion GOBEC

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