The Integrity Playbook: Strategies for Ethical Management.
A Training Guide to Help Managers and Executives to Lead With Integrity, Ethically and Effectively.
Why do we need it?
Per the U.S. Department of Justice ("DOJ"), the Criminal Division's Evaluation of Corporate Compliance Programs memorandum was updated in September 2024 to include guidance on the design of the Compliance Program, among other things. The question that guides the principles around the structure of the Compliance program is: "Is the Corporation's Compliance Program Well Designed?"
The DOJ notes that the critical factors in evaluating any program are whether it is adequately designed for maximum effectiveness in preventing and detecting wrongdoing by employees and whether corporate management is enforcing the program or tacitly encouraging or permitting employees to engage in misconduct.
If we teach employees of all levels of management to be more sensitive about ethics, compliance, and integrity, we are enhancing the effectiveness of the Compliance Program and Company Culture. This process is worked on overtime at all levels of the Company. We can not expect results without doing the work. The Integrity Playbook aligns with the DOJ's expectation of an effective Compliance Program.
"Accordingly, prosecutors should examine the comprehensiveness of the compliance program, ensuring that there is not only a clear message that misconduct is not tolerated..."
This language was directly transcribed from the DOJ memo about Training and Communications:
“Another hallmark of a well-designed compliance program is appropriately tailored training and communications. Prosecutors should assess the steps taken by the Company to ensure that policies and procedures have been integrated into the organization, including through periodic training and certification for all directors, officers, relevant employees, and, where appropriate, agents and business partners. Prosecutors should also assess whether the Company has relayed information in a manner tailored to the audience's size, sophistication, or subject matter expertise.”
“Prosecutors, in short, should examine whether the compliance program is being disseminated to, and understood by, employees in practice in order to decide whether the compliance program is "truly effective."
The Integrity Playbook specifically concentrates on teaching managers at all levels how to integrate Company Values, Ethics, Compliance, and Integrity into everyday practice, it is an easy to follow hands on guide.
Currently many companies uphold their Company Values, Mission Statements, and Company "Code of Conduct," also known as the "Code of Ethical Business Conduct" or "Code of Ethics." This document, which we will refer to as the "Code of Conduct," plays a pivotal role in shaping the ethical fabric of the organization.
Company Values are the fundamental principles that guide the organization, such as integrity, respect, accountability, and teamwork.
A Code of Conduct is a set of guidelines and rules that outlines the expected behaviors, values, and ethical standards for individuals within an organization or community. It serves as a decision-making framework and helps maintain a positive and productive environment.
Employees are generally introduced to the Company Values and the Company Code of Conduct at some point early on during their employment. Most companies ask employees to certify receipt of the Code of Conduct and complete the Code of Conduct training.
Some companies explicitly designate their managers as Ethics Leaders in their Code of Conduct, acknowledging their additional responsibilities. While this is a positive step, it's important to remember that it's just the beginning.
For this notion to be accurate, it [Ethics Leader information] can't be included in the Code of Conduct and not communicated further. If companies expect managers to be true Ethics Leaders, they must acknowledge this in the Code of Conduct and invest in their education on Ethics and Compliance. We have found that very little work is done to educate supervisors and managers on what it means to be an ethics leader.
Understanding and shaping corporate culture is a key aspect of ethical leadership. Leaders must have a clear vision of the desired culture and a deep understanding of the current one.
"Most leaders I've met share the desire to deliver results, care deeply for their teams, and make ethical decisions. Yet, these goals can feel challenging—especially when the pressure is high." ~ Tobias Sturesson
This means having tough conversations about the successes and failures of the culture, company values, and everything in between. Tobias Sturesson wrote in his book "You Can Culture," where he named the first chapter - Get Humble. "You Can Culture" is an excellent book.
To "get humble" generally means to adopt a humble mindset. This adaptation process can involve recognizing one's limitations, being open to learning from others, and valuing the contributions and perspectives of those around you. It often includes letting go of arrogance or pride, being willing to admit mistakes, and showing gratitude for the support and help of others. Humility fosters better relationships, enhances personal growth, and promotes a more collaborative and understanding environment.
Based on the essential discussions with leadership mentioned earlier, the Company must determine its strategic direction for the Company, including Culture, Values, and Code of Conduct.
For this article, we will assume that the Company recognized that initiatives needed to change the overall culture and create a culture of Ethics, Compliance, and Integrity at all levels. This is the beginning: the top leaders recognize that something must be done and support the program.
What is the program? The Integrity Playbook: Strategies for Ethical Management. What does this mean? The program aims to empower all managers to live and breathe ethics, compliance, and integrity, making it a part of their and the Company's DNA.
Some companies include a paragraph about Managers' responsibility as Ethical Leaders in the Code of Conduct. The problem is that many times there is no discussion or training for managers to understand what this title means. It is simply text printed in the Code without any guidance.
It is essential to include a point about Ethical Leadership from the beginning of employment or even plant the seeds during the interview process; this practice will set the tone. At a minimum, Companies should discuss Company Values, Compliance Programs, and Ethical Leadership during on-boarding training. Set the expectations. The Integrity Playbook: Strategies for Ethical Management. A Training Guide to Help Managers and Executives Lead With Integrity Ethically and Effectively provides step-by-step instructions on how to be an Ethics Leader, Who is it, What it Means, and How to get it done.
The expectation is that managers are trained to converse with their employees about Ethics, Compliance, and Integrity by utilizing tools provided by the Compliance Department; these tools are developed for the Company based on the Company's risk assessment. This Playbook provides suggestions for topics, frequency, and other tools to assist managers with becoming Ethics Leaders and planning and creating space to bring Ethics and Compliance into frequent conversation. The Integrity program's vision is that the Company, leadership, and managers, with the support of the Compliance Department/Program, provide an ongoing conversation with employees on Ethics, Compliance, and Integrity.
Managers are not expected to create all the materials for discussions with their employees on their own. Instead, they will be provided with resources from this Playbook, the Compliance Department, or newspaper headlines covering relevant topics on Ethics, Compliance, and Integrity. We aim to enhance knowledge and ethical awareness throughout the Company through frequent conversations. Managers will become more sensitive to E&C topics; they will be better equipped to answer employees' questions, understand when to report issues to appropriate channels, or bring up issues to Compliance, HR, or Legal Departments. Integrity Playbook provides information on active listening, sensitive issues, and a reporting guide, among other information, and many tools available to managers for their utilization.
This way, together, we will integrate Ethics, Compliance, and Integrity into the company's Culture at all levels.
If you are interested in learning more about the Integrity Playbook, please email to info@ethicaledfeexperts.com