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TABLE OF CONTENTS
Index of Supporting Resources..........................................................4
Communicating with Integrity...........................................................4
Category
Ethical Tone
Model Ethical Behavior
Honesty and Integrity
Communicate Compliance
and Ethics Expectations
Carefully Listening to
Opinions of Others
Openness to New Ideas
Friendliness and
Approachability
Holding Peers
Accountable
Accepting Responsibility
for Successes and
Failures
Taking Action upon
Unethical or
Inappropriate Behaviors
and Practices of
Employees
Action
Create the appropriate environment for your staff by
emphasizing corporate values in your words, actions,
and deeds.
Model the behaviors in your Code of Conduct to
employees and discuss why this is important.
Ensure that your words and action align to give staff
confidence that you walk the talk when it comes to
compliance and ethics values, policies, and procedures.
Set clear behavioral expectation amo ng staff and train
them on the policies and laws relevant to the business
units operations.
Seek to understand staff needs and desires while
actively soliciting opinions and ideas. Take the time to
follow-up on particular needs.
Encourage employees to bring forward problems or ideas
by regularly asking their opinion and providing them an
audience with senior management.
Cultivate relationships with staff and ensure
approachability by keeping an open door. Encourage
employees to bring forward any problem, disagreement,
question, recommendation or comment.
Clarify compliance and ethics performance expectations
with staff and hold them strictly accountable for
successes and failures. Never justify unethical or illegal
acts by claiming that they helped the bottom line or
were directed by a higher authority in the organization.
Take responsibility for group failures while
acknowledging the success and contributions of team
members.
Establish clear disciplinary guidelines and uphold them in
all situations to ensure that employees believe in
organizational commitment to company action when
there are instances of misconduct.
*For additional information about these guidelines, see the Councils Ethical Leadership
Self-Assessment.
Reporting Concerns
Cutting Costs
Potentially Damaging: Think outside the box when managing rising costs this year.
Not balancing the budget will significantly affect your bonus.
Preferable: While I want you to focus on managing rising costs, remember that
honesty comes first. The cost of breaking the rules is too great.
Hitting Numbers
Potentially Damaging: Everyone has to hit their numbers this year. Senior
management will not accept any excuses.
Preferable: It is crucial that were all working together to reach our goals this year.
But remember: this company do es not take short cuts. Always put integrity ahead
of numbers.
Setting Deadlines
Potentially Damaging: I dont care what part you use. Just make sure the
prototype is done by Friday.
Preferable: I want this prototype by Friday, but I dont want you cutting any
corners. Is that manageable?
Potentially Damaging: Why cant I get Steve to create reports like this?
Preferable: Im really impressed with your work on this project. Nice job.
Working Abroad
Potentially Damaging: See what you can do to get this approved. Things work a
little differently over here.
Preferable: Look into the standard practice for getting approval here. I know things
work a little differently over here, but well have to make sure it complies with
company standards.
*Source: Crafting a Message that Sticks: An Interview with Chip Heath, McKinsey Quarterly,
November 2007, Lenny Mendonca and Matt Miller.
Ensure that you dont end up lecturing employees. Create an open dialogue with
them about relevant compliance and ethics issues.
Example: Choose one employee each month to spend a few minutes of a staff
meeting leading a compliance and ethics discussion.
Focus on key risks to the business so employees realize that youre not just going
through the motions but actually protecting the business.
Example: Highlight compliance and ethics issues that are a historic or emerging risk
to the specific business or function in which you work.
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I want to use the last few minutes of our meeting today to talk about business
ethics. I want you to know how important ethical conduct is in this job, not only
because of company policy, but also because it is good for business. I dont expect
you all to know the Code of Conduct word-for-word, but you should be aware of the
policies and procedures that are relevant to you. Lets practice applying what you
know with some examples that dont necessarily have a clear right answer.
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When writing the annual report, you include a footnote that explains an unusual
earnings number. Your supervisor deletes the footnote because the explanation
complicates the report. If the numbers are correct without the footnote, should you
pursue the issue?
Sales
There is extra money in the advertising budget at the end of the quarter and you
notice that your supervisor has recorded entertainment expenses as business
advertising expenses. You have always been impressed by your supervisors strong,
clear commitment to ethics. Does it matter if the expenses are recorded in the
correct category as long as the numbers are right?
Marketing
You have prepared a presentation on a new company promotion. You are excited
about the plan but worry that it wont resonate with the younger audience. You
want to discuss it with a longtime friend outside the company, a marketing
consultant who is an expert with this customer segment. Should you discuss the
plan with your friend?
Operations
A fellow employee informs you that many company employees do not properly
report minor workplace accidents because the disclosure affects their performance
reviews. Performance reviews are rolled up so the low number of accidents helps
you and your supervisor. In fact, your supervisor has won an award for safest
operation. The reporting employee is ultra-competitive and will stop at nothing to
get ahead. Should you pursue the employees claim?
Human Resources
You have a friend who wants you to compile a list of e-mail addresses of people at
your company who may be interested in his bus iness. You figure that they may like
the offer and want to help your friend, and no one would ever know you gave him
this information. Should you send the list of e-mails to your friend?
IT
You are working with a consultant in a password protected area o f the company
intranet. You must leave to take care of an urgent problem, and the consultant
offers to finish the research and logoff afterwards. Youve worked with the
consultant for several years and consider him to be completely trustworthy. Should
you accept the consultants offer?
*For additional examples, see the Councils Library of Ethical Dilemmas.
Use Compliance and Ethics Business Cases presentations to highlight Compliance and
Ethics importance to individual employees.
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13
You notice that a plant operations manager uses her company phone and cell phone
for frequent personal calls. She has two young children, one of whom gets fevers
regularly. Is the manager justified in using company phones for personal calls?
An employee is hospitalized, and a rumor spreads that she fell ill from a leaky pipe
in the workplace. Employees demand to know the circumstances of her illness as
they fear that they may also be at risk. The employee is suffering complications due
to an abortion and has asked you, her supervisor, to keep the terms of her sickness
confidential. What should you do?
You supervise a contractor doing renovation work at your company. The contractor
suggests that since he has extra time, he could do some work on your home at a
deep discount. Youve had trouble finding a good contractor and the renovation
work is top-notch. You insist on paying the full rate. Should you take the offer?
Your supervisor asks you to skip a few minor quality checks to make a strict
deadline. You provide the quality checks every day and there is never a problem.
Should you follow your supervisors instructions?
As the year comes to a close, you realize that your operation has already exceeded
the profit target in its annual business plan. Since your bonus is based only on
meeting the yearly target, you wonder if you should hold any further income
received that year off the books to get a head start on the next year. What should
you do?
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Your supervisor has you send free merchandise to an important government official.
You agree because you know this is commonplace in interactions with government
officials in this country and that company employees have been doing it for years.
Should you have agreed to send the merchandise?
You discover that your groups performance has significantly increased since you
began to go out for extended lunch breaks to discuss current business challenges.
One member of the group has difficulty walking to lunch and requests that the
group no longer talk business during lunch if she is not there. What should you do?
Investigations Dilemmas
You overhear two colleagues discussing that the company is considering acquiring a
small, publicly traded firm. You wonder if it is okay to acquire some of the firms
stock. You figure it is only a rumor, and even still, nobody knows you had heard it.
Should you buy the stock?
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2.
Does our work group have a climate in which diverse perspectives are
valued?
3.
Do you feel that the company has your best interest at heart?
Manager Engagement
4.
5.
6.
Employee Engagement
7.
Does your job make good use of your skills and abilities?
8.
Do you feel encouraged to come up with new and better ways of doing
things?
9.
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* If you are asked to facilitate a training session and would like to develop your skills
further, please contact your compliance and ethics or learning and development officer for
support.
18
From:
To:
Cc:
Subject:
[Name]
Staff
Compliance Training
Dear Team,
As you may know, we will conduct compliance training over the coming week. During this [one]hour session, we will discuss the importance of ethical decision making in our business lives as
well as a few specific compliance topics including [Ex: Harassment, Insider Trading, FCPA, etc.].
We place a great deal of emphasis on conducting business in an ethical manner for which we can
be proud. I would like to reiterate the importance the company places on compliance and ethics. It
is for this reason that I ask all of you to participate in this upcoming training session. It should be a
productive hour focused on company expectations and a conversation about your experiences,
concerns, and difficulties. I look forward to seeing everyone at the training next week.
Sincerely,
[Name]
*For additional examples, see the Councils Compendium of Compliance- and Ethics-Related
E-mails.
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Identify how many people are to be trained and organize them into groups [if
necessary].
Select three or four ethical dilemmas that are appropriate for your group
[See Councils Library of Ethical Dilemmas].
Reserve a room with enough tables and chairs for comfortable seating.
Send participants a meeting notice with the time and place for the session.
Send the notice sufficiently in advance to allow participants time to plan their
schedules.
Review the leaders opening and closing remarks. Feel free to personalize the
messages.
Write down the name and phone number of your local Compliance and Ethics
Officer (if applicable). This information will be given to the participants.
Dont wait until youre in the room to figure out how to facilitate the training.
Do take the time to review the included materials and select the cases that
are the most relevant to your group.
Dont forget to arrange people in teams before you review the cases.
Do arrange the teams so that participants can easily discuss the cases
among themselves and between teams.
Dont let people sit out the session without participating or let one or two
people dominate the entire discussion.
Do take the initiative to get everyone involved in the activity and keep the
conversation flowing around the room.
*Source: Lockheed Martin Corporation; Compliance and Ethics Leadership Council research.
20
Your role in the train ing is to introduce the topics and foster a productive
conversation among staff. In fact, the goal of training is to foster a dialogue about
the compliance issues and ethical dilemmas that employees face.
Choosing Cases
Research has indicated that discussions centered around employee concerns that
outline typical work scenarios are most effective. It is therefore recommended that
you choose case examples that will resonate with your staff. Before presenting
training, identify several cases to illustrate the point of the session. Use CELCs
Library of Ethical Case Scenarios and Questions to assist in this effort.
Discussing Cases
Spend three to five minutes describing each scenario and raising a central ethical
challenge. Foster a discussion with participants around the ethical issues involved in
the case and how the situation should be resolved. To that end, managers should
present ethical dilemmas and create a conversation about:
After the discussion, have the participants vote on the best outcomes and discuss
the choice.
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22
III. REINFORCING
THE
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Following a corporate compliance and ethics message, managers can provide rolespecific information to their employees by focusing on issues that are especially
relevant to their day-to-day work or tie into business strategy.
Example: Explain how a new companywide policy will impact the business units
standard operating procedures when working with clients abroad.
Line managers provide a local voice for explaining the background behind corporate
initiatives and their importance to the organization. This keeps employees aware of
their obligations while engaging them with the company as a whole.
Example: Explain how the company develo ped a speaking-up policy to deal with
employee concerns about retaliation, which was revealed through a companywide
survey.
24
Risk Assessments
Internal Audits
Speaking-Up Campaign
State your personal support for the compliance and ethics message (as
discussed in training).
25
Using speaking-up and training campaigns for examples, this section provides
language that a manager can use to discuss a corporate compliance and ethics
initiative.
[Name]
Staff
Speaking-Up Campaign
Team,
I want to follow up on the e-mail you recently received from the compliance and ethics office to
express my support for this campaign and let you know that Im here to answer any questions you
may have. While the speaking-up campaign stresses the use of the company help line to report
perceived misconduct, my door is always open if you would feel more comfortable discussing your
concerns with me. You should always feel safe raising concerns without any fear of retaliation.
This is very important to me as it is a key part of making this a successful business and a great
place to work.
Thanks,
[Name]
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[Name]
Staff
Speaking-Up Campaign
Team,
I want to follow up on the anti-corruption training you just took to highlight a few relevant points
that relate specifically to our business.
Driven by your desire for more discussion, I will hold a Q&A session this Thursday on the
topic of anti-corruption and the FCPA. All questions are welcome.
Only a few years ago in this office, the company refused to pay the Labor Officer bribes to
obtain approval to allow women to work second shifts. The company pleaded their case to
the Labor Minister. Ultimately, permission was granted.
We will be taking the following steps to integrate the companys FCPA policy into our
business:
o Incorporate compliance risk assessment into the strategic planning process
o Incorporate contractual safeguards into contracts
o Provide education when working with third parties
Thank you all for participating in this very important training session. FCPA compliance is crucial
to this companys success, especially in our business. I look forward to seeing you at the Q&A
session this week.
Best,
[Name]
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Watch your tone of voice and body language (i.e., demonstrate due attention
to employee concerns).
29
Managers should use standard criteria to determine when identified incidents need
to be escalated to the corporate office. All incidents should be communicated to
local HR. Typical escalation criteria include the following:
Issues which could have a negative public relations impact for the company
30
From:
To:
Cc:
Subject:
[Name]
Staff
Internal Investigation
31
32
33
Its not unnatural for people to be defensive or feel the need to make excuses for
their poor performance. You can help prevent these instances from becoming
confrontational by listening to their counterpoints. Sometimes the excuses are
valid, sometimes not. In either case, you can use this part of the discussion as the
groundwork for building a plan together for closing this performance gap.
Begin to develop a plan for addressing the performance weakness and provide an
overview of how you plan to support your employee through this process. You may
also take this opportunity to discuss your expectations for the next review cycle.
Even if the conversation has been tense, make sure you provide a summary that
includes performance strengths.
*Source: Corporate Leadership Council research; Compliance and Ethics Leadership Council.
34
Detail examples of desired compliance and ethics attributes in action to clarify for
the employee the types of actions that should be taken. Rewards or
acknowledgement create positive incentives for exemplary behavior.
*Sourc e: Corporate Leadership Council research; Compliance and Ethics Leadership Council.
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36
Ask why the violation occurred. Does the employee feel that these violations
occur frequently?
Assure the employee that the violation is behind him or her, but that a
repeat offense will result in severe consequences.
Increased Absenteeism
Changes in Productivity
37
Allegation
Categories
Primary
Functional
SME
Accounting/Auditing
Fraud and Internal
Accounting Controls
Adequacy/Integrity
of Books and
Records
Disclosure Controls
Money Laundering
Insider Trading
Internal
Audit
Advertising and
Promoting to
Consumers
Legal
Commercial Bribery
Legal
Environmental
Safety/Quality
Product
Safety
Fair Competition
Legal
Secondary
Functional
SMEs
- Corporate
Compliance
and Ethics
- Legal
- Information
Security
- Corporate
Security
- Corporate
Controller
- Global
Advertising
- Customer
Relations
- External
Relations
- Internal
Audit
- Corporate
Compliance
and Ethics
- Legal
- External
Relations
- Corporate
Security
- Internal
Audit
- Corporate
Compliance
and Ethics
1st
Offense
Min
2nd
Offense
Max
1st
Offense
Min
2nd
Offense
Max
38
Allegation
Categories
General Code of
Conduct
Conflicts of Interest
Breach of Confidential
Information
Electronic Media Use
Gifts and
Entertainment
General Legal and
Regulatory Issues
Anti-Trust
Government
Contracting/Pricing
Employee Relations
Discrimination
(Age/Race/Gender/
Religion/Disability)
Harassment (Sexual
or Other)
Inappropriate Conduct
in the Workplace
Improper Use of
Company Assets:
Computer or
Information Loss
Improper Use of
Company Assets:
Equipment, Supplies,
Credit Card, Time
Abuse
Improper Use of
Company Assets:
Misappropriation of
Assets
Improper Use of
Company Assets:
Property Damage or
Theft
Primary
Functional
SME
Secondary
Functional
SMEs
1st
Offense
Min
2nd
Offense
Max
1st
Offense
Min
2nd
Offense
Max
Corporate
Compliance
and Ethics
- Corporate
Security
- Legal
- Human
Resources
Legal
- Corporate
Compliance
and Ethics
- Corporate
Security
Human
Resources
- Legal
- Corporate
Compliance
and Ethics
Information
Security
- Corporate
Security
- Customer
Relations
- Privacy
Human
Resources
- Corporate
Security
- Internal
Audit
Internal
Audit
- Corporate
Security
Corporate
Security
- Human
Resources
39
Primary
Functional
SME
Privacy
Legal
Security
Workplace Theft/
Violence
Employee Safety
Corporate
Security
Transnational Laws
Anti-boycott and
Embargo Laws
Foreign Corrupt
Practices Act
Trade Control
Legal
Secondary
Functional
SMEs
1st
Offense
Min
2nd
Offense
Max
1st
Offense
Min
A*
- Human
Resources
- Informatio
n Security
- External
Relations
- Corporate
Compliance
and Ethics
- Human
Resources
- Internal
Audit
2nd
Offense
Max
40
[Name]
Staff
Disciplinary Action
41
[Name]
Staff
Internal Investigation
42