Use Compliance Training and Code of Conduct to Encourage “Ethical Emotion” in Your Culture


I just returned from the lovely city of Washington DC where I spent the last three days with many ethics and compliance professionals at Compliance Week 2014.  This is my first time attending the conference, although The Network has been a sponsor for two years.  It was wonderful to see several clients and prospects and to hear from dozens of subject matter experts on topics close to my heart, like compliance training, policy management processes, compliance management systems, anti-bribery training techniques and enforcement trends.

Many of the sessions were engaging and informative; I have about a dozen blogs running through my head!  I was typing like crazy on the flight back to Atlanta.

One session I attended was about some surprising compliance training statistics – more to come on that in future blogs.  A gentleman from Booz Allen Hamilton was on the panel and showed the diagram below as his company’s model for their ethical culture.


I was really inspired by the simplicity of the image and how the company was able to express the components of its ethical culture in a simple equation: ethical emotion + ethical reasoning + efficacy, all wrapped in trust.

I particularly liked how the company acknowledges the “feel” aspect of culture. The panelist noted how important it is to understand that culture is not something you – or your employees – just think about, or just do – it’s something you and they feel.   I hadn’t heard that in the ethics and compliance context before, but it’s true.  I had lunch the other day with a friend who is interviewing for a new job and the first thing he said about this new company he’s interviewing with is “I like the culture.”  When I asked him what he could really tell about the culture after a few interviews he replied “I don’t know, it’s just how it feels there.”  He used that word FEEL.

The Importance of Emotion in Compliance Training

Why is it important to acknowledge that?  Because when you understand how employees digest your culture, you can tailor your communication and awareness vehicles accordingly.   Take compliance training as one example.  Most ethics and compliance training already focuses on the THINK and the DO.  I bet your sexual harassment training course clearly explains to employees how to apply sound reasoning and think through a situation to identify whether it’s misconduct and how to actually do the right thing and report it.  But does it incorporate ethical emotion?  Does it encourage employees to see that situation in an ethical context and with the appropriate empathy?

When you understand how employees digest your culture, you can tailor your communication and awareness vehicles accordingly. Share on Twitter

Or does it go a step further and recognize the other emotions that could come into play; I’m sure someone witnessing this kind of behavior and realizing that he or she has to report it will deal with a whole host of emotions.  If it were me, I imagine I’d feel disappointment in the individual committing the misconduct, gratitude that I had good sexual harassment training to guide me, fear that reporting the issue could come back to haunt me in some retaliatory way… acknowledging to employees that yes, doing the right thing is often emotional, prepares them for what they may feel and can help them deal with that when the time comes.  We’ve noted before that a speak-up culture instills confidence in employees, while a closed culture breeds fear and misconduct; admitting the emotions involved in ethical situations can certainly contribute to a speak-up environment.

A speak-up culture instills confidence in employees, while a closed culture breeds fear and misconduct. Share on Twitter

Of course there are so many other vehicles by which you build and communicate your culture to your employees and you can incorporate ethical emotion into many of them.  The next one that comes quickly to my mind is the Code of Conduct.  As the place where you first establish the standards of behavior that you expect from your employees, the Code is naturally heavily focused on the DO.  Can you incorporate some of the FEEL?  Is there a place within the Code where you can show the employees that you recognize the emotional component to building your ethical culture and that you encourage employees to embrace it?  I would also think that somewhere in your policies you can express your organizations’ desire to see employees act with empathy and to always see decisions in an ethical context.

Culture can be very nebulous, amorphous; distilling it to a simple, easy-to-digest graphic like Booz Allen Hamilton has is a great way to share it with employees.  It’s one thing for the leadership to say (via “tone from the top” – I’m guessing you’ve heard that phrase before) “we’re committed to an ethical culture,” but it’s another thing to actually show a picture that includes the components they use and the way of feeling, thinking and acting that contribute to building that culture to a high ethical standard.

I will be writing more throughout the coming days on many of the great insights I gathered during the Compliance Week 2014 conference. 



DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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