Building a strong culture and tone at the top is essential to truly minimise ethics and compliance risk in a company, but it is easier said than done. HOW do organisations ensure that the tone at the top is aligned with the compliance and ethical standards they seek? HOW does that get assessed? HOW can we enhance the culture of our organisation so that it encourages the right behaviour and trust?
These are some of the tough questions we tackled last week at Compliance Week Europe, a two-day conference in Brussels that brought together diverse leaders from some of the most reputable multinational and leading regional companies to address regulatory and political issues that necessitated increasing agility on the Chief Compliance Officer’s (CCO) part. Speakers and attendees shared practical examples, insights and revelations into the frontline issues faced by compliance professionals in Europe. I had the pleasure of moderating a practical and gritty panel discussion packed with take ways entitled “Assessing Your Organisational Culture.”
Joining me on the panel were Zoe Bramham, Governance Manager at Imperial Brands and Jeff Stitt, Chief Compliance Officer at GE Steam Power. Both Zoe and Jeff identified that the single most important question you can ask your workforce to assess your organisation’s culture is whether people feel able to report concerns without fear of retaliation. They were able to draw on their considerable practical experience assessing culture across international programs as they shared best practices around considering the tone across different levels of their organisation.
Zoe spoke about the importance of values and the need to challenge the norm. She felt that a values-based code of conduct was needed to codify the right behaviours and focus the business on “how” we do things. Jeff took us through the GE ‘Risk Roll Up’ assessment which GE undertake annually and the need to start as a CCO with the authority to fire the top sales person should he or she behave contrary to the code of compliance and ethics of the organisation.
We also heard about the need to create an environment of wanting to change behaviours, HOWthe pressure needs to be on the managers to encourage doing the right thing, and HOWthe right tone at the middle is key.