Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a post on corporate culture and employee surveys.  Her profile can be viewed here.  She can be reached at lconnell@volkovlaw.com.

It is always amazing to me how reluctant people are to ask direct questions. Interviewers freeze up when they have to ask the big question – “Did you steal the money?” Boyfriends are afraid to ask a girlfriend, “What is the future of our relationship?”

When it comes to corporate culture, there is a simple and direct way to find out how your company is doing – ask your employees? It does not cost very much; it does not require hiring outside consultants; and it can be done relatively quickly.

A culture of ethics and compliance is an invaluable asset. It depends on the leadership of the company and has to be preserved and promoted. It is the best protection against misconduct – if effectively embedded, an employee considering cutting corners or doing something wrong will hopefully think twice and even stop because of the company’s culture.

Business surveys routinely confirm that companies with a culture of ethics and compliance have lower rates of misconduct, fewer incidents where employees feel pressured to do the wrong thing, and higher rates of employees reporting misconduct.

With a strong culture you don’t need to depend solely on rules and policies to inform employees of company expectations; employees understand the company’s expectation and will try to do the “right thing,” recognizing that the company is committed to integrity.

The best part for compliance professionals is that culture is relatively cheap. You don’t have to maintain hundreds of pages of compliance programs forms and policies when your company has a strong ethical culture. You don’t have to spend hundreds of thousands of dollars training employees on the rules when they instinctively know that doing things the right way is the best way. You just have to repeat over and over, and have your executives and managers do the same, that this company does things the right way and that this company won’t stand for unethical behavior.

Maintaining a culture of ethics requires vigilance and monitoring. An employee survey is an effective tool to measure a company’s culture. Chief Compliance Officers should conduct multiple annual surveys, not of the entire workforce but targeted surveys in response to risk.

Designing an employee survey requires care and attention. It should be targeted to the values and principles at the core of the company’s fabric. Management has to communicate the importance of the survey and the results as an important piece of information to promote the company’s culture.

The questions do not have to be complex. If you promise anonymity and make it easy to fill out (online-based) you should get a decent response rate.

To focus on corporate culture, employees should be asked if:

• The company shows a commitment to ethical business decisions of conduct;
• The employee knows how to report unethical business practices;
• The employee feels pressure to compromise ethical or compliance standards to get the work done;
• The employee feels comfortable reporting a violation of the company’s policies or standards;
• The employee feels comfortable reporting potential misconduct without fear of negative consequences; and
• The employee has the support needed to the get the job done ethically