Lessons from Rome

Mary Bennett of the Ethical Leadership Group wrote three lessons we can learn from the ancient Roman army:

First, there is the timeless importance of culture. People in a society or organization will behave according to the most widely accepted common denominator, modeled by those at the top. We must train and communicate with our leaders so they get this.  So that they can communicate and stress the importance of this culture on the organization

Second, we must realize that human behavior is motivated by both the carrot and stick. Roman soldiers got paid if they followed the rules; they got executed if they did not. A simple and effective approach. We may not be able to adopt this exact approach in our ethics and compliance efforts.  But must be sure to reward good behavior as well as discipline bad behavior. Do both consistently.

Third, good controls are a must. The Roman army minimized its risks through clear rules, repeated training, and swift reinforcement with the carrot and stick. What worked in Rome can work in your organization through your ethics and compliance efforts.

Assessing Corporate Culture

Ed Petry of the Ethical Leadership Group put together a two part paper on Assessing Corporate Culture: Assessing Corporate Culture – Part I and Assessing Corporate Culture – Part II.

[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?