Workshop Slides

Implementing Ethics in the Workplace: Creating the Process
(Abridged version)
a program of the Greater Omaha Business Ethics Consortium
at Creighton University
Sponsored by
The Seven Sentencing Guidelines

1. Having Standards 2. Assigned Responsibility - Adequate Resources 3. Due diligence in Hiring 4. Communications and Training 5. Monitoring, Auditing, Reporting 6. Promotion and Enforcement of Ethical Conduct 7. Reasonable Steps to Prevent Misconduct
The Challenge is Doing More with Less

1. Have a Plan - preferably a long range plan 2. Have support at the Top and an Ethics Team 3. Get an Ethics/Compliance Committee Chartered 4. Put in place a Code of Conduct 5. Get a Helpline Set Up 6. Communicate to Managers/Employees 7. Do Some Training - E-Mail,Web,Video, 8. Attend Other Meetings or Training Sessions 9. Give Leaders Ethics Messages to Send Out 10. Use the Company Website Extensively 11. Follow in the Wake of Critical Events 12. Regularly Report on Numbers, Issues to Mgt.
Every Company is Unique

Leadership History Culture Policies Practices People Regulatory Environment
Gallup Organization Findings
Tone at the Top

VALUES
One of the Seven Demands of Leadership
Gallup Research Based Findings

During nearly forty years of research and tens of thousands of interviews, Gallup has determined the Seven Demands of Leadership.
These are behaviors of individuals who are perceived as leaders within their organizations, communities and nations.
GOBEC www.omahaethics.org
WHAT GREAT LEADERS DO MOST - the most commonly expressed demands

Gallup Organization VISIONING
7 D E M A N D S
MENTORING
BUILD A CONSTITUENCY CHALLENGING EXPERIENCES
MAKING SENSE OF EXPERIENCES

STABILIZING VALUES KNOWING SELF
Allocation of Time For Creating Alignment

Gallup Organization
Typical
90-100%
Drafting & Redrafting Statements
0-5%
Identifying Core Values
0-5%
Creating Alignment
Desired
10-20%
Identifying Core Values
0-5%
Drafting & Redrafting Statements GOBEC www.omahaethics.org
80-90%
Creating Alignment
Organization and Personnel
How to Manage Organizational Ethics?

1. Create a formal program w/resources 2. Put someone in charge of it
General Counsel HR director Internal auditor
Report to
CEO Board of Directors Committee of the Board of Directors Senior Executive
Support for Managing Organizational Ethics Programs

Ethics and Compliance Officer Association
http://www.theecoa.org/
Compliance with Laws
SWEET SPOT
Ethical Behavior
Compliance and Ethics Program
BCBSNE Compliance Organization

Board of Directors
Audit & Compliance Committee Corporate Compliance Officer (VP Level) Compliance Department (with dedicated Staff) Compliance Cross Functional Team Members
Responsibilities
1. Provide Guidance and Answer Questions
Create and Assist in Creating Policy & Procedure Develop and Deliver Training Foster Awareness & Encourage Ethical Behaviors
2. 3. 4.
Respond to Auditors and Regulators Respond to Complaints (Receive/Investigate/Document/Resolve) Liaison with the Board of Directors
Listen
Report
5.
Keep Current on and Facilitate Compliance with Laws and Regulations

Communication & Training

Getting the right message out
What is communicated?
Ethics Materials:
Mission Values Code of conduct/ethics Policies Decision methods Your culture
Ethics program:
Who is the Ethics Officer? How to make contact?
Senior Management Commitment to Ethics:
Why organizational ethics matters?
Methods of Communication
Evaluate current ethics communication lines
Formal and informal downward, upward, and two way
Clear, consistent, credible messages across communication lines

More about Methods of Communication

Hiring Announcements Website Email Brochures Meetings Formal & Informal Orientation sessions Newsletters Manuals Code Handbooks w/certifications Badges and Wallet Cards Key Fobs
Ethics Training
Design for individual groups Groups:
new recruits existing employees top management local management
Ethics Training
Live Computer based Trainers Certification
Helplines/Hotlines
Getting Started, Outsourcing, Case Management, Operational Flow, Processes, and more Factors and Features
Introduction
What is a helpline/hotline and what do you need to do to establish one? Why set up a helpline/hotline? Who should answer the line? How does a helpline/hotline work? When can you expect to fully implement a helpline/hotline? Free Advice vendor selection, positioning, themes, questions
What. A Helpline/Hotline Is and Some Alternative Reporting Mechanisms

Helpline. a confidential toll-free telephone number for employees or others to report suspected violations of law or company policy and to answer policy questions Hotline focuses on the reporting of suspected violations and emergencies
Consider departmental needs/requirements (Safety, EEO, Audit, Environmental, HR)

Evolution of reporting channels
From post office boxes To confidential faxes To voice mailboxes To confidential e-mails To web-based reporting systems
What . You Need to Establish a Helpline

Senior Management Support and some Money Understandable Guidelines for using the Helpline that Reflect your Organizational Values and Policies Multi-function support (Communications, HR, IT, Law, EEO, Operating, Audit, etc.) Designated Support Personnel Accountability and follow-up Communications and Employee Awareness
Union Pacifics Values Line

Established in 1994 and is outsourced (third-party service) Covers 55,000 employees
Is a business conduct report line

Does not primarily support Safety, Emergencies, Environmental, Payroll or HR services (internal lines) Supports EEO, Audit, Policy and Employee Relations reporting
Why.Set up a Helpline or Hotline?

Understand the objectives Increased emphasis on organizational ethics and compliance carrot and stick incentives Establish formal monitoring, auditing and reporting systems Provide anonymous channel for reporting suspected violations (which may otherwise be unreported) Raise awareness of commitment to ethical conduct Establish a proven, effective tool for protecting company
Why Set up a Helpline or Hotline? Legal and Regulatory Requirements

Federal Sentencing guidelines One of seven steps in an effective ethics and compliance program SEC implementing rules New York Stock Exchange proposed listing requirements
Sarbanes-Oxley Act (enacted 2002)

Sections 301 and 806
Who . should answer the line? Decision Process

External
24/7/365 Anonymity Multilingual Perceived confidentiality Vendor Features
Internal
Staffing/budget Time constraints Employee trust Knowledge of Policies Translation services? Training/Turnover Software
Who?.Analyzing Vendors
Vendor Selection Process
Talk with people who have lines Visit Vendor Websites Review intake process/procedures Request proposals, review best practices Include your IT department
Perhaps absorb existing call system(s)

Consider hidden costs, extra reporting
How. Does a report line work?

- Call is placed to the UP Values Line designated toll-free number (800-998-2000) OR shared toll-free number Helpline personnel records information according to general protocol or your specific design (EEO, FMLA, etc.) Classifications, information, key issues Case is reported to you and/or others via e-mail or web links Case management data is summarized each month or through ad hoc reports
Operational Key Points

Spread Out the Work Expect 1-2% of Employees to call/yr Who Calls the Line? Types of Calls, Categories Anonymous versus Identified (20/80) Sufficient Investigation Resources No Retaliation for good faith reporting Confidentiality to extent possible Follow up is essential
Types of Values Line Reports Jan. 1 - Aug. 31, 2006

Theft & Drugs 1% Pay 4% Safety 4% Union/CMS/Discipline 6% Smoking 1% Supervision/Relations 66% Policy 11% Job Perf./Fitness Threats/violence 0% 3% Other 1%
Supervision/Relations Discrim./Harass. Policy Smoking Union/CMS/Discipline Safety Pay Theft & Drugs
Discrim./Harass. 3%
Threats/violence Job Perf./Fitness Other
Butch Ethington Ombudsman 402-544-2113
595
Questions?
Cost $1,500 to $30,000+ per year + your time Reports see handouts Vendors The Network, EthicsPoint, Lighthouse,
Allegiance, and many more. See handouts of hotline best practices
Helping to maintain a culture of integrity
Enforcement
Ensuring Observance Putting into practice Making it happen
Enforcement
Reality: Codes and rules without enforcement and adherence are useless. Question: How do we ensure compliance with legal rules and corporate policies?
Why should you enforce?

You have Two Choices: Corporate Enforcement Government Enforcement The best enforcement is self-enforcement! Better your company do it than the EEO, SEC, IRS, court, etc.
Types of Enforcement
The best policy is to prevent wrongdoing
1. Getting Compliance (preventative)

Training and Education (I didnt know) Review: Audit for compliance and quality Incentives: compensation and recognition Model: Leadership talks, and walks the talk
2. Punishment (responsive)
Clear Sanctions in place Ethics Committee (method in place) Someone with oversight responsibility
Implementing Enforcement
Consistency is Important across Firm
Cross-check from HR for termination issues
Codified Policy is helpful Yet, Flexibility is important also Realize Firing is sometimes correct action for sake of firm. Unions usually have process/expectations
Correcting Problems
Sentencing Guidelines also require that you have a method of remedying ethical problem areas in your corporate culture
Examples:
Ethics committees Ombudsman Ethics Officer Stated Corporate Policy On Correction Procedure
The Seven Sentencing Guidelines

1. Having Standards 2. Assigned Responsibility - Adequate Resources 3. Due diligence in Hiring 4. Communications and Training 5. Monitoring, Auditing, Reporting 6. Promotion and Enforcement of Ethical Conduct 7. Reasonable Steps to Prevent Misconduct
Wrap Up Discussion

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Workshop Slides

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Implementing Ethics in the Workplace: Creating the Process

The Seven Sentencing Guidelines

The Challenge is Doing More with Less

Every Company is Unique

Gallup Organization Findings

Tone at the Top

Gallup Research Based Findings

WHAT GREAT LEADERS DO MOST - the most commonly expressed demands

MAKING SENSE OF EXPERIENCES

Allocation of Time For Creating Alignment

Organization and Personnel

How to Manage Organizational Ethics?

Support for Managing Organizational Ethics Programs

Compliance with Laws

Compliance and Ethics Program

BCBSNE Compliance Organization

Keep Current on and Facilitate Compliance with Laws and Regulations

Communication & Training

Who is the Ethics Officer? How to make contact?

Senior Management Commitment to Ethics:

Why organizational ethics matters?

Clear, consistent, credible messages across communication lines

More about Methods of Communication

What. A Helpline/Hotline Is and Some Alternative Reporting Mechanisms

Consider departmental needs/requirements (Safety, EEO, Audit, Environmental, HR)

What . You Need to Establish a Helpline

Union Pacifics Values Line

Is a business conduct report line

Why.Set up a Helpline or Hotline?

Why Set up a Helpline or Hotline? Legal and Regulatory Requirements

Sarbanes-Oxley Act (enacted 2002)

Who . should answer the line? Decision Process

Perhaps absorb existing call system(s)

How. Does a report line work?

Operational Key Points

Types of Values Line Reports Jan. 1 - Aug. 31, 2006

Threats/violence Job Perf./Fitness Other

Butch Ethington Ombudsman 402-544-2113

Helping to maintain a culture of integrity

Why should you enforce?

1. Getting Compliance (preventative)

The Seven Sentencing Guidelines

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