By: Evie Wentink, Principal, Ethical Edge Experts
In a LinkedIn post, I saw a poster that read, “If your employees are afraid to speak up, your culture is broken.” I had to share this poster with a comment that said, “Everything—I mean Everything—in Compliance comes back to or starts with the culture!”
Let’s think about that for a minute or two. What does that mean? How do you know if you have it or not? Can you measure it? How? We will explore these Company Culture questions as we go on.
How can companies measure Compliance Culture? Yes, there are always surveys. Some surveys will note how much employees know about the Compliance Program, with questions like: Do you know your hotline number? Do you have policies? Are you aware of your Company’s Compliance Program? Do you know who the Chief Ethics Officer is? Does your company have an Open-Door Policy? Then, we can also ask if employees know of any instances of Conflicts of Interest, fraudulent activity, harassment, or discrimination, and we can also ask questions about these activities. Consideration should also be given to open-ended questions if employees want to provide additional information.
Finally, we want to determine how the employees feel about their working environment. “Surveys” can be a touchy subject, as Human Resources often gives employee engagement surveys and may think there are too many surveys for the employees. HR will suggest that survey fatigue is a real thing.
Measuring the survey results over time can show us the direction in which the company is heading in terms of the employees’ Culture. It is essential to start somewhere; a baseline survey is a good beginning. After that, the same survey should be given annually to review the trends.
That is one way we can review the Culture. But have you learned about what is happening inside your company from a survey? Is that enough to understand your Culture?
The answer is no.
Someone once said, “It’s about the Tone at the Top, the mood in the Middle, and the Buzz at the bottom.
When it comes to the Tone at the Top, who your leaders are matters. Compliance culture is like family dynamics; employees look up to the leaders, like children who look up to their parents. Leaders need to understand this notion and expect everything they do in company/employment and private life to be a direct reflection of themselves. What will the employees see? Are you [leader] walking the walk?
Stop for a minute and think about this. What if your life was written in headlines?
Many leaders will say they are too busy with some things… and are forced to cut corners. It’s like the game of a telephone; what begins at one end as a benign instance may end on the other end as a catastrophic event. Today’s leaders are expected to do the right thing, always. They ought to live like celebrities in every instance because someone is always watching.
The mood in the Middle: Our managers have the same responsibility as our leaders; they must also lead by example. Understanding the responsibility of the manager and leader roles is where Compliance professionals come in with training, arming managers and leaders with the power of knowledge.
Both leaders and managers need to be behind supporting the Compliance Program; it starts with attending and participating in certain Compliance-sponsored events, providing employees with time to attend these Compliance events, completing their required Compliance training, and communicating with employees about their completion of the Compliance Training requirement, supporting Compliance initiatives and oversight, working with Compliance professionals on new strategies for better compliance program, providing the appropriate resources, etc.
It all has to come full circle.
When reviewing completion training records, the departments with leaders who take it seriously achieve near 100% completion success. Think about that. When your boss takes the training, and I know everyone complains about mandatory annual training, but if the boss takes it, the people who work in his department have no excuse. We are all busy.
Now, the buzz. Remember the buzz at the bottom we mentioned earlier? We want to know what employees say, but how can we find out? We spoke about surveys. Another way we can measure our Culture and hear the buzz is by the calls we receive on the hotline. What is coming in? Are you receiving any calls, too little or too many? Are these calls valid hotline complaints, or are many not substantiated? This data says something; it tells us much about what comes in and how. How is it received, investigated, and answered? Do you benchmark the data over time?
One of the best ways to investigate and learn about what is on everyone’s mind is to have a conversation. During an in-person or small group video training, the presenter can engage the group once the presentation on some specific topic is completed; the best thing a company can do is to leave time for questions and conversations. Pay attention to these conversations and or questions now that the “investigation of the buzz” begins. Take a note. What are the employees interested in or curious about? My firm belief is that when we hear something, it may trigger an idea or question that wouldn’t typically cross our minds. We listen to the conversations; we pay attention. That is where we uncover “the buzz,” the things we would not generally learn about unless we were close with the employees. We need to create an environment to make employees feel comfortable asking questions and having conversations.
The poster said, “If your employees are afraid to speak up, your culture is broken.” Here, what do we mean, when, and how? The Compliance culture is only broken if the employee doesn’t know how to reach us, literally and figuratively. If the employee knows how but chooses not to, the Culture is broken. Everything begins and ends with Culture.