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 www.omahaethics.org WHAT GREAT LEADERS DO MOST - the most commonly expressed demands
Gallup Organization 7 D E M A N D S VISIONING MENTORING BUILD A CONSTITUENCY CHALLENGING EXPERIENCES MAKING SENSE OF EXPERIENCES
STABILIZING VALUES KNOWING SELF GOBEC www.omahaethics.org Allocation of Time For Creating Alignment Gallup Organization Typical 0-5% 90-100% 0-5%
Drafting & Redrafting Statement s GOBEC www.omahaethics.org 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 www.omahaethics.org Report to CEO Board of Directors Committee of the Board of Directors Senior Executive
GOBEC www.omahaethics.org Support for Managing Organizational Ethics Programs Ethics and Compliance Officer Association http://www.theecoa.org/ GOBEC www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org Methods of Communication
Evaluate current ethics communication lines Formal and informal downward, upward, and two way Clear, consistent, credible messages across communication lines GOBEC www.omahaethics.org More about Methods of Communication
Key Fobs GOBEC www.omahaethics.org Ethics Training Design for individual groups Groups: new recruits existing employees top management local management GOBEC www.omahaethics.org Ethics Training Live Computer based
Trainers Certification GOBEC www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org Types of Values Line Reports Jan. 1 - Aug. 31, 2006 Theft & Drugs 1% Pay 4%
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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org 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 www.omahaethics.org
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