New Year’s Resolutions for the Compliance & Ethics Community
Here are three resolutions I’d love to see the ethics and compliance community adopt for 2010.
First, let’s promote innovative approaches to regulation that are less descriptive of process, and focus instead on real accountability. For example, SOX mandated an anonymous reporting channel for employees to report financial fraud or misconduct. Consequently, businesses adopted some form of a hotline, which barely moved the needle in encouraging people to report misconduct. But what if the government had said to corporations: “We want you to demonstrate through employee surveys that three-quarters of your workers are willing to report misconduct they may have witnessed?” Senior managers would have had to make the creation of ’speak-up’ cultures a high priority. And I bet we would have seen a massive change in employees’ willingness to speak up.
Second, let’s devote a fraction of the time and money we collectively spend on ethics and compliance and finally launch a comprehensive study on how to create performance management systems which actually promote ethics, compliance and responsible conduct instead of impeding them. We know that this issue is at the very heart of creating ethical cultures, so why aren’t we addressing it?
And, third, let’s take another look at our training programs and make sure that they are actually effective at accomplishing the objectives of our ethics and compliance programs. Let’s make sure we’re not just communicating the “what” but the “why” and the “how” which are critical to creating ethics culture change. And while we’re at it, let’s replace the term “training” with “education” with a stated goal of empowering employees to become ethics leaders, not just followers of the corporate rules.
Now here’s my prediction for 2010: We won’t do any of the above. Unfortunately, positive risk-taking and innovation have never been hallmarks of our ethics and compliance community, and so we will content ourselves to make small changes around the margins instead creating fundamentally new solutions to old problems which have been festering for decades.
And my challenge? Prove me wrong!



