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“Ethics is knowing the difference between what you have a right to do and what is right to do.” Potter Stewart
If someone were to ask you how ethical your organization is, would you know the answer? If you responded ‘no’, you wouldn’t be the only one. Just as the Seven Elements of an Effective Compliance Program must be woven into the fabric of your organization, ethics must be as well. In fact, ethics should be woven into each of the 7 elements. So how do Compliance professionals navigate some of the ethical challenges that seem to appear in the toughest of times? That answer isn’t one size fits all.
Navigating the world of business ethics can seem straightforward but it may not always be. Ethics are the rules that govern our decisions on a daily basis. They are gut feelings and judgement calls that are reacted to daily in varying degrees. Some may ask how a person becomes ‘ethical’ and in turn ‘unethical’. Is the process of being ethical passed down by family, faith, and community? Is it instilled in each of us based on our organizations guidelines in which we work or the laws put in place to govern our cities, states, and country? I suppose it may be a combination of all of the above. Ethics is the internal code that each of us has engrained in our being that guides our decisions.
So how does a person or organization become unethical? Is it gradual resulting from many small, intentional oversights that lead to a much more largescale, systemic issue? Do employees lose their moral compass over time, chipped away little by little over the course of a career? It could be both but it could also be a lack of leadership and examples being set within the organization.
As Robert Noyce once said, “If ethics are poor at the top, that behavior is copied down through the organization.” When an employee’s back is against the wall and profits are needed to meet year-end quotas or goals, the one thing that must come into play with each decision is ethics. A Compliance professional’s job is to understand their organization and be able to recognize where the ethical risks may exist and mitigate them before an unethical decision is made. Compliance teams must remain proactive.
An organizations Compliance and Ethics Program should include policies related to professional conduct expected of all employees. Ethics may also be covered in your organizations Code of Conduct. Regardless of whether the information is in the Code of Conduct or outlined in a standalone policy, the document should offer guidance on how to handle common ethical problems that employees might face, specific to the organization. Additionally, employees should feel empowered to discuss problematic situations with managers as well as a way to confidentially report issues such as the use of an Employee Hotline.
In business, ethics must be kept at the forefront of the core operating principles, spoken from the top down and intertwined into every aspect of the organization. As Warren Buffett once said, it takes 20 years to build a reputation and five minutes to ruin it. If you think about that, you’ll do things differently.
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