When Corporate Culture Makes You Cringe Common and Not-So-Common Mistakes When Building a Corporate Culture Ed Petry, Ethical Leadership Group SCCE, September, 2007 Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 1 Why Today’s Emphasis on Corporate Culture? The DOJ’s H/T/M Memo - indicting a company may be necessary “to be a force for positive change of corporate culture” SEC - emphasized “that firms need to create a culture of compliance….” Guidelines - “promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.” Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 2 1 Why Today’s Emphasis on Corporate Culture? • Culture trumps compliance • Culture is the chief factor in determining the effectiveness of your ethics and compliance program Q: How Was Culture Incorporated into The Guidelines? - Key Factors … Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 3 Key Factors Impact on Ethics Program Whether there is consistency and clarity regarding the limits of acceptable behavior. The extent to which the Board and all managers act in accordance with their responsibilities to build and sustain a commitment to ethics. Whether ethics or even legal requirements – or the people responsible for them at a company – are marginalized. Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 4 2 Key Factors Impact on Ethics Program Whether performance goals and incentives encourage and put unreasonable pressure on employees to act contrary to ethics standards. The ease with which employees can ask questions or raise concerns. Whether bad conduct is tolerated – especially at the senior level. Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 5 Key Factors Impact on Ethics Program Is the ethics/compliance message actually reaching employees? Do employees believe that it is possible to behave ethically and achieve objectives at the company? Do employees understand and trust the upward communications channels available to them? Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 6 3 Your Role Identify Existing Corporate Culture (s) Assess Cultures with Respect to Risk Implement Plan to Build, Revise Culture to Support Ethical Decision-making and the Ethics and Compliance Program Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 7 “One Bank” B of A and MBNA Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 8 4 Common and Not-So-Common Mistakes How Does This Happen? • Lack of Perspective • Strong Desire to Fit-In • No One Tells the Emperor … • Dissent Discouraged – “That’s Not How We Do Things Here” Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 9 Common and Not-So-Common Mistakes Warning Signs: Is Your Culture Only Understood by Insiders? Best Kept Private? Pass the Spouse Test? Has it Driven Employees Underground? Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 10 5 Common and Not-So-Common Mistakes Well Intentioned, Yet Cringe-Worthy A Case Study Improve Customer Service Encourage Empathy Day-Long Values Training Empathy Listening Skills Self-Awareness, Root Out “Negativity” Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 11 Common and Not-So-Common Mistakes Positives: Demonstrated Company Commitment Created a Common Language Raised Awareness and Values-Literacy Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 12 6 Common and Not-So-Common Mistakes Negatives: Created “Company-Speak”, Insiders/Outsiders Driven Many (?) Employees Underground Gave Senior Leadership False Sense of Security Marginalized the Ethics Program Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 13 Common and Not-So-Common Mistakes Imposed, Top Down, Insiders’ (Narrow) View One Size Fits All Not Risk-Based Supporting Ethics Not Part of Design Identifies Values and Culture with Emotions Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 14 7 Common and Not-SoCommon Mistakes Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 15 Moving Ahead Describe, Assess, Improve Preliminary Assumptions Identifying and Describing The Survey Problem Build a Culture that Supports Ethical Decisions and Supports the Ethics Program Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 16 8 Preliminary Assumptions Don’t Assume You Already Know More than a Slogan, May Not be Captured by Your Values Recognize Multiple Sub-cultures: Senior Leadership Regional Acquisitions Business Units, Functional Areas Generational Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 17 Look for Cultural Drivers Cast a Wide Net: Written and Unwritten Rules History CSR, Philanthropy Traditions, Folklore and the “Grapevine” Customs and Routines Perceptions Beyond Employees Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 18 9 Look for Cultural Drivers Cast a Wide Net: What Does Senior Leadership Say What Do Others Hear, Especially Middle Managers Mixed Messages, Perks and “the little things” Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 19 Look for Cultural Drivers Cast a Wide Net: HR Practices Recruiting Material Exit and Entrance Interviews Incentives Performance Reviews Discipline Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 20 10 Some Red Flags for Us… Leaders “unavailable” to meet with us Poor attendance, arrive late/leave early, or poor attention at focus group meetings No questions, no curiosity Secrets, “elephants in the room” Employees lingering or returning “to chat” Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 21 A Caution: Internal Surveys The More Demographics the Less Reliable Leading Questions “Do You Know that You Can call Anonymously…” Survey Fatigue Trust Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 22 11 A Caution: Internal Surveys Manipulation/Preparation “We Know What answers we need to have…” Worse when Used in Performance Reviews Conflict Avoidance “The wrong answers mean more training, more attention” “I don’t want to get anyone in trouble” Reluctance to Share Dirty Laundry with Home Office Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 23 On-Going Describe your Culture and Subcultures Maintain Broad Perspective Integrate with Risk Assessment Periodically Reassess Build a Culture that is Understood by All to be a Strategic, Business Asset and that Supports Ethics Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 24 12 Questions? Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license 25 13
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