When Corporate Culture Makes You Cringe Why Today`s Emphasis

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
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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
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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
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Key Factors
Impact on Ethics Program
Œ
Whether there is consistency and clarity regarding
the limits of acceptable behavior.
Œ
The extent to which the Board and all managers act
in accordance with their responsibilities to build
and sustain a commitment to ethics.
Œ
Whether ethics or even legal requirements – or the
people responsible for them at a company – are
marginalized.
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Key Factors
Impact on Ethics Program
Œ
Whether performance goals and incentives
encourage and put unreasonable pressure on
employees to act contrary to ethics standards.
Œ
The ease with which employees can ask questions
or raise concerns.
Œ
Whether bad conduct is tolerated – especially at the
senior level.
Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license
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Key Factors
Impact on Ethics Program
Œ
Is the ethics/compliance message actually
reaching employees?
Œ
Do employees believe that it is possible to behave
ethically and achieve objectives at the company?
Œ
Do employees understand and trust the upward
communications channels available to them?
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Your Role
Œ
Identify Existing Corporate Culture (s)
Œ
Assess Cultures with Respect to Risk
Œ
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
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“One Bank”
B of A and MBNA
Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license
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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
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Common and Not-So-Common
Mistakes
Warning Signs:
Œ
Is Your Culture Only Understood by Insiders?
Œ
Best Kept Private?
Œ
Pass the Spouse Test?
Œ
Has it Driven Employees Underground?
Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license
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Common and Not-So-Common
Mistakes
Well Intentioned, Yet Cringe-Worthy
A Case Study
Œ
Œ
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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
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Common and Not-So-Common
Mistakes
Positives:
Œ
Demonstrated Company Commitment
Œ
Created a Common Language
Œ
Raised Awareness and Values-Literacy
Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license
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Common and Not-So-Common
Mistakes
Negatives:
Œ
Created “Company-Speak”, Insiders/Outsiders
Œ
Driven Many (?) Employees Underground
Œ
Gave Senior Leadership False Sense of Security
Œ
Marginalized the Ethics Program
Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license
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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
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Common and Not-SoCommon Mistakes
Copyright 2007, Ethical Leadership Group All rights reserved. May be used only under license
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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
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Preliminary Assumptions
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Don’t Assume You Already Know
More than a Slogan, May Not be Captured
by Your Values
Recognize Multiple Sub-cultures:
Ž
Ž
Ž
Ž
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Senior Leadership
Regional
Acquisitions
Business Units, Functional Areas
Generational
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Look for Cultural Drivers
Cast a Wide Net:
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Written and Unwritten Rules
History
CSR, Philanthropy
Traditions, Folklore and the “Grapevine”
Customs and Routines
Perceptions Beyond Employees
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Look for Cultural Drivers
Cast a Wide Net:
Œ
Œ
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What Does Senior Leadership Say
What Do Others Hear, Especially Middle
Managers
Mixed Messages, Perks and “the little
things”
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Look for Cultural Drivers
Cast a Wide Net:
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HR Practices
Ž
Ž
Ž
Ž
Ž
Recruiting Material
Exit and Entrance Interviews
Incentives
Performance Reviews
Discipline
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Some Red Flags for Us…
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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”
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A Caution: Internal Surveys
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The More Demographics the Less Reliable
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Leading Questions “Do You Know that You
Can call Anonymously…”
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Survey Fatigue
Œ
Trust
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A Caution: Internal Surveys
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Manipulation/Preparation
Ž “We Know What answers we need to have…”
Ž Worse when Used in Performance Reviews
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Conflict Avoidance
Ž “The wrong answers mean more training, more
attention”
Ž “I don’t want to get anyone in trouble”
Œ
Reluctance to Share Dirty Laundry with Home
Office
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On-Going
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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
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Questions?
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