Workshop Slides SHT 02

Implementing Ethics in the
Workplace:
Creating the Process
(Abridged version)
Sponsored by
a program of the
Greater Omaha Business Ethics Consortium
at Creighton University
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
7
D
E
M
A
N
D
S
VISIONING
MENTORING
BUILD A CONSTITUENCY
CHALLENGING EXPERIENCES
MAKING SENSE OF EXPERIENCES
STABILIZING VALUES
KNOWING SELF
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Allocation of Time
For Creating Alignment
Gallup Organization
Typical
0-5%
90-100%
0-5%
Identifying
Core Values
Drafting & Redrafting

Statements
Creating
Alignment
Desired
10-20%
0-5%
80-90%
Identifying
Core Values
Drafting &
Redrafting
Statements
Creating
Alignment
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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
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Report to
CEO
Board of Directors
Committee of the Board of Directors
Senior Executive
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Support for Managing

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

Board of Directors
Audit & Compliance Committee
Corporate Compliance Officer (VP Level)
Compliance Department (with dedicated Staff)
Compliance Cross Functional Team Members
.org
Responsibilities
1.
Provide Guidance and Answer Questions
Create and Assist in Creating Policy & Procedure
Develop and Deliver Training
Foster Awareness & Encourage Ethical Behaviors
2.
Respond to Auditors and Regulators
3.
Respond to Complaints (Receive/Investigate/Document/Resolve)
4.
Liaison with the Board of Directors
5.
Listen
Report
Keep Current on and Facilitate Compliance with Laws and Regulations
.org
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?
.org
Methods of Communication
Evaluate current ethics communication lines
Formal and informal
downward, upward, and two way
Clear, consistent, credible messages across

communication lines
.org
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
.org
Ethics Training
Design for individual groups
Groups:
new recruits
existing employees
top management
local management
.org
Ethics Training
Live
Computer based
Trainers
Certification
.org
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
.org
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
.org
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

.org
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
.org
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

.org
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
.org
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
.org
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
.org
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
.org
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
.org
.org
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
.org
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?
.org
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.
.org
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
.org
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
.org
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
.org
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
.org

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Implementing Ethics in the

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

These are behaviors of individuals who

WHAT GREAT LEADERS DO MOST

Drafting & Redrafting

Organization and Personnel

Support for Managing

Compliance and Ethics Program

BCBSNE Compliance Organization

Provide Guidance and Answer Questions

Create and Assist in Creating Policy & Procedure

Develop and Deliver Training

Foster Awareness & Encourage Ethical Behaviors

Respond to Auditors and Regulators

Respond to Complaints (Receive/Investigate/Document/Resolve)

Liaison with the Board of Directors

Keep Current on and Facilitate Compliance with Laws and Regulations

Communication & Training

Who is the Ethics Officer? How to

Why organizational ethics matters?

Clear, consistent, credible messages across

More about Methods of

What. A Helpline/Hotline Is and

From post office boxes

What . You Need to Establish a

Senior Management Support and some Money

Understandable Guidelines for using the Helpline that Reflect your

Multi-function support (Communications, HR, IT, Law, EEO,

Designated Support Personnel

Accountability and follow-up

Communications and Employee Awareness

Union Pacifics Values Line

Understand the objectives

Increased emphasis on organizational ethics and compliance

Establish formal monitoring, auditing and reporting systems

Provide anonymous channel for reporting suspected violations

Raise awareness of commitment to ethical conduct

Establish a proven, effective tool for protecting company

Why Set up a Helpline or Hotline?

Federal Sentencing guidelines One of seven steps in an effective

SEC implementing rules

New York Stock Exchange proposed listing requirements

Sarbanes-Oxley Act (enacted 2002)

Who . should answer the line?

How. Does a report line work?

Operational Key Points

Spread Out the Work

Cost $1,500 to $30,000+ per year + your time

Reports see handouts

Vendors The Network, EthicsPoint, Lighthouse,

Helping to maintain a culture of integrity

Why should you enforce?

1. Getting Compliance (preventative)

Training and Education (I didnt know)

Clear Sanctions in place

Codified Policy is helpful

The Seven Sentencing Guidelines

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