By Roy Snell
roy.snell@corporatecompliance.org
I just read another article asking the question, what was more important, following the rules or building an ethical culture? It sounded like the guys who used to say, “Go beyond compliance to ethics.” You cannot build an ethical culture if you don’t follow the rules. If you don’t follow the rules and put out the, “We are an ethical company” video, people will become bitter.
The article did mention that “ethical culture” was a vague term or hard to define. The article said it’s not enough to talk about an ethical culture; you have to understand it and bring it into alignment. Say what? Sounded like corporate speak to me. I wrote a tongue and cheek article in corporate speak. Here is part of that article.
“We will empower our employees to synergize our constituency. We will do the right thing by creating an ethical culture beginning with tone at the top to ensure our core values are aligned with our performance integrity standards. Ultimately we will mitigate the enterprise-wide risk with our governance, risk and compliance plan. Our values-based performance Gant Chart will be mapped to our compliance program maturity model.”
“In summary, we will boil the ocean to increase our learnings and ensure our business ecosystem is scalable. If we execute, we will be able to establish our running game and dominate the line of scrimmage by pounding it out on the ground. However, if that dog won’t hunt, we will herd the cats until the cows come home. Everyone except my cat will be asked to think outside the box. This project will take us from cradle to grave… very soon.”
I was a little sarcastic to make a point. People are not impressed with corporate speak or theoretical discussions. They are impressed by actions. VW’s problem might have been an ethical issue. However, what they needed was a compliance program to find and fix the ethical problem. Penn State knew about their problem for 10 years but lacked a compliance program that would find and fix their ethical problem. You could argue that if they were ethical, the problem would not have occurred in the first place. But that’s never going to happen. Problems will always occur. And if all you do is try to build an ethical culture you will fail. You have to look for, find, and fix problems before you can build an ethical culture.
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In both your examples: VW and Penn State, the base issue was profits. In so many situations upper management is verbally supportive of a compliant and ethical tone at the top, until the need for refunding comes up or the termination of a particularly high admitter has to be undertaken due to whatever. The first example matches up with VW’s position on the diesel emissions issue and the second lines up with the Penn State debacle.
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