Nature Or Nurture? Use Code of Ethics Training, Annual Culture Assessments to Nurture Ethical Culture


I’ve been getting more involved with our company’s social media presence lately, which is quite the double-edged sword. On the plus side, my team is very happy, I’m finding loads of great content and wonderful subject matter experts to follow. On the downside, where is all my time going? I swear, I log on to Twitter and the next thing I know, three hours have disappeared. I’ve even started logging on after dinner, much to the chagrin of my husband… and the pile of laundry that’s waiting on me. Ok, make that piles, plural.

At any rate, culture, social media, ethics and Code of Ethics training are some of my favorite topics and wow, I’ve found loads of great dialogue, blogs and thoughts on those topics, just this week alone.

I found an article I loved by The Red Flag Group, which they published in their “Business Insider,” called “How to Nurture a Culture of Ethics.” You know that we at The Network feel very strongly about not just creating, but maintaining, an ethical culture, which is why I loved seeing the word NURTURE in the title. It shows that the author already realizes ethical culture is not something that is built, implemented and then left alone; it requires care and feeding.

Ethical culture is not something that is built, implemented and then left alone; it requires care and feeding.

The author explains why having an ethical culture is important, this way: “Without a culture of ethics employees are afraid to speak up and are pressured to cut corners to ‘just get the job done’… A culture of ethics makes employees feel that acting ethically is the right thing to do.”

I think that’s well put. It’s about putting “doing the right thing” above everything else. Is that easier said than done? I wouldn’t call it easy but the author goes on to give some great advice about how to not just create, but again to nurture, an ethical culture.

First, like with most things, define what you are trying to do. What does an “ethical culture” mean to your organization? How will you measure whether or not you are successful? I’ve blogged about how Apollo Group measures their culture by breaking it down into 5 measurable components. Those may not be the same components you measure, but you have to define them up front.

Second, conduct a culture assessment by surveying your employee base; this will give you enough data get an accurate picture of the culture and establish a baseline. You may want to use a third party so employees feel comfortable that their responses are confidential, which will encourage them to be as truthful as possible.

Again, thinking in terms of ‘nurture’… conduct that same survey every year, so you have trending data and can easily see whether you are moving in the right direction.

Third, identify areas to focus on and then communicate to your employees… this is the area that speaks to me the most. The author breaks this area into three specific parts, which I’ll take a bit of liberty with:

  • Marketing Campaigns – Creating a culture of ethics – or nurturing, or improving one, will depend upon open communications with employees. One of my colleagues in our Training & Communications area likes to say “compliance needs to think like Marketing” and as a marketer, I know what she means. You will identify cultural improvements you need to make; the next step is to put together what is essentially a marketing campaign to your employees. As an example, if you discover that employees are unaware when policies are updated or when Code of Ethics training is happening, put together a marketing campaign with that messaging and with the employees as your prospects. Think like a marketer. You can use all the vehicles marketers use: emails, newsletters, messages from leadership; perhaps include a video introduction message from the CEO in your Code of Ethics training. On another note, an ethical culture depends on employees trusting their leadership so be honest with them, even when the news isn’t good.

Are you running your Code of Ethics training and compliance programs like marketing campaigns?

  • Tone from the Middle – We hear an awful lot about “tone from the top” in the ethics and compliance world, but a ton of influence is held in the middle. Because employees look to their direct managers as an example of how to act, the way managers behave is incredibly important in terms of its effect on the culture. Managers should receive targeted Code of Ethics training and awareness efforts as a vehicle for change. The author states “While general audience communication programs can be effective on some level, seeing a strong example set by middle management can be the most reputable and effective catalyst for culture change.” The tone from the top is also very important, as senior executives must lead by example, walk the talk and regularly communicate with employees about the importance behaving ethically. There’s nothing worse than an inauthentic leader, preaching one thing and behaving another way. American Apparel, anyone?
  • Facelift – Finally, give the program a facelift with a rebranding effort. The written documents, policies, online experiences, training, compliance software… present everything employees need to read in a clear, concise, easy-to-digest way. Anything in legalese will not be understood. And if it’s not understood, don’t you start the problem cycle all over again? By making content more user-friendly, you draw employees in, help them remember the information more easily and reduce risk by increasing the chances that they remember it.


It’s not easy to change a culture that’s entrenched in the employees of a company – it practically becomes part of the company’s DNA. Many employees are hesitant to change. But even incremental improvements can have a very positive impact, and the rewards for having an ethical culture are so great: improved reputation in the marketplace, happier and more productive employees, and according to Ethisphere and many others, there is a lot of data showing that more ethical companies out-earn less ethical companies in terms of revenue.

Have you, or do you plan to conduct a culture assessment? Do you measure your company’s ethical culture? I’d love to hear your thoughts… right after I finish that laundry.


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