[There are] specific steps that compliance and ethics officers can take to begin the process of identifying their organizations’ culture including:
• Conduct surveys, focus groups and interviews of employees and third parties to determine what people really think about the organization, what motivates them, what’s rewarded and punished, and what are the “unspoken rules” and corporate stories that they believe best illustrate acceptable and unacceptable behavior;
• Distinguish and describe the important subcultures within the organization; and
• Identify what is really being heard by employees – which may be quite different from the message you and senior management are intending to convey.
You should do deep dives that follow roughly track the elements of the revised Sentencing Guidelines:
- Is there consistency and clarity within your organization regarding the limits of acceptable behavior?
- Does the Board and management act in accordance with their responsibilities to build and sustain a commitment to ethics and compliance?
- Is compliance, ethics or even legal requirements – or the people responsible for them at the company – marginalized?
- Do performance goals and incentives encourage and put unreasonable pressure on employees to act contrary to ethics and compliance standards?
- Do employees feel they can ask questions or raise concerns?
- Is bad conduct tolerated – especially at the senior level?