COMPLIANCE CORNER: Going Beyond the Rules
By Brian Fields, chief ethics and compliance officer, Structure Tone
How often do you follow certain rules only because “those are the rules”? Chances are, it is simply because actually understanding these rules is more of a hassle. Following these rules is a formality that must be completed before moving on to the business at hand.
Alternatively, how often do you follow rules because they represent values you respect and want to advance, because you understand and appreciate their purpose or because you feel a personal connection to the goals they promote?
Some companies treat compliance and ethics as a set of rules to be mindlessly followed. They create libraries of ethics policies and put processes in place to prevent unethical behavior. Their leaders instruct employees to read those policies and require them to tick a box confirming that they did. Those policies are quickly forgotten until they must be read again the following year, and another box is ticked.
Establishing a library of policies and procedures should be a component of any company’s ethics and compliance program. But creating a culture of compliance goes well beyond a collection of rules and a check-the-box attitude. A true culture of compliance includes training, incentives, financial controls, third-party diligence, awareness campaigns and other elements that ingrain compliance and ethics into every practice and process of the business.
Most importantly, it takes engaged employees. No “rule” or “policy” will ever take the place of an engaged employee who truly wants to do the right thing. As put by author Frank Herbert, “Give me the judgment of balanced minds in preference to laws every time.” Engaged employees are not simply “following the rules”—they challenge outdated practices and are internally motivated to do the right thing. They understand the personal and professional value in acting honestly. They appreciate the hazards of acting unethically. And, perhaps most critically, they are personally vested in promoting the company’s culture of integrity.
In the last several years we’ve seen dozens of leading companies in various industries—automotive, finance, pharmaceutical, you name it—get into hot water for alleged ethical breaches. These large corporations surely had compliance departments complete with ethics policies. But, that may be where they stopped, neglecting to invest in the most important component of a high-quality compliance program: a culture of integrity. For whatever reason, their leadership and the employees supporting them still went ahead with unethical behavior, despite the ethics policies and the many boxes that surely had been ticked.
A company’s culture of integrity must be promoted every day, and words alone won’t do it. It takes a commitment from the company’s leaders to go beyond simply saying, “We are an ethical company,” to actually promoting and modeling ethical behavior. It takes a compliance program that elevates the company’s values above an assemblage of procedures. And it takes engaged employees personally vested in promoting a culture of integrity. These employees are not “following the rules;” they are following an internal compass far more powerful than any policy could ever be.