Ethics Today Online
Published
by the Ethics Resource Center
July 20,
2006 Volume 4, Issue 5

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A Word from the President: Measuring Ethical Culture
If on your summer vacation, you decided
to stop in with the family and visit the designated ethics and compliance
officer at all the organizations along your travel route, aside
from the fact that you'd wear out the good will in your family,
you would see that most organizations have a few things in common
when it comes to their approach to ethics. Just over 85% of organizations
across the US have codes of conduct, and 81% of organizations have
a mechanism to hold people accountable to those standards. Other
commonalities are the presence of anonymous reporting lines and
training programs on topics in ethics and compliance. It's not so
awfully surprising that organizational ethics and compliance programs
have these elements in common. For over a decade, organizations
have designed their ethics and compliance programs based upon recommended
elements in the Federal Sentencing Guidelines for Organizations
(FSGO). Not only has FSGO helped create an industry standard, but
until very recently, if you had the FSGO recommended elements of
an effective program in place, you could be reasonable confident
that you had an effective program in place.
Simply having the elements of a program
in place, however, is like getting ready for your summer road trip.
Packing your bags, gassing up the car, and mapping out your route
don't mean that your trip will actually turn out the way you've
planned (especially if there are kids involved). Similarly, from
the perspective of the US Sentencing Commission and FSGO, having
program elements no longer means that you have an effective program.
The FSGO 2004 revisions (FSGO 2004) now specify that program due
diligence includes "periodic measurement of program effectiveness."
Simply put, even if you have the mechanisms of a program in place,
you must now show that your program actually works. Organizations
should be able to demonstrate that their programs are effective
and actually achieve outcomes generally expected of an ethics and
compliance program. In addition, FSGO 2004 states that organizations
should "otherwise promote an organizational culture that encourages
ethical conduct and a commitment to compliance with the law."
In other words, a program that works can meaningfully demonstrate
that it is fostering an ethical culture within the organization.
But how does one demonstrate the effectiveness
of an ethics program? And, more problematically, how does one identify
and measure ethical culture?
These questions form the framework
for ERC's current research agenda, which has a multi-pronged approach.
First, based on our decades of working
closely with organizations on ethics and compliance issues, ERC
has developed measures of culture and effectiveness through employee
surveys and a rigorous methodology to collect reliable data. We
have the capability to generate community- and industry- specific
benchmarks, allowing us to understand ethics program effectiveness
based on a number of different indicators.
Second, we've developed new ways to
expand our datasets, and I'm pleased to announce a new "Donate
Your Data" program, which allows companies to donate to ERC
data accumulated from their internal surveys which deal in whole
or in part with ethics and compliance. Our enriched overall data
set allows ERC to formulate thoughtful research pieces on topics
that are important to business leaders, such as ethical culture
and the effectiveness of training programs.
Third, our Fellows Program Measurement
working group has identified two critical topics to address: Measuring
the Impact of Culture with an emphasis on the Effects of Leadership
at Varying Levels in the Organization; and Measuring Training Effectiveness.
The working group members meet on a monthly basis to share insights,
best practices and organizational experience in measuring training
and program effectiveness.
In addition, ERC has started disseminating
its findings, beginning with a series of webcasts presented in May
and June on "Understanding, Affecting and Measuring "Ethical
Culture." ERC research staff and guest speakers presented three
online seminars on "What Is Known About "Ethical Culture"
and Why We Should Care," "The Impact of Leadership on
Ethical Culture," and "Measuring Ethical Culture."
A synopsis of these webcasts, which identifies many of the key issues,
is included below.
As we look ahead, we anticipate that
these programs will serve as the solid groundwork for meaningful
research on the topic of measuring ethics program effectiveness
and ethical culture. In the meantime, we trust that the contents
of this issue will help you to think about how you can frame your
own measurement efforts.
Patricia J. Harned, Ph.D.
ERC President
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**ERC
Webcasts on "Understanding, Affecting, and Measuring Ethical
Culture”
In May
and June, ERC researchers and guest speakers presented a series
of three 1˝ hour web-based seminars on the ethical elements of organizational
culture, or ethical culture.
ERC Senior Project
Manager Abby Davidson presented the first webcast on "What
is Known about Ethical Culture and Why We Should Care," including
discussion of the elements of organizational culture and the impact
of ethical culture on outcomes.
She cited the following as examples of ethical culture:
- What are the values that drive how
things are really done around here?
- How much pressure is there to perform,
and to cut corners to do so?
- Are employees surprised when misconduct
occurs?
- How confident are employees that
executives are committed to ethics as fundamental to doing business?
- How much do people talk about the
importance of ethics?
- Are managers trusted to keep promises
and commitments?
She also discussed the impact of Ethics-Related
Actions (ERA's), which include such things as communicating about
ethics, setting positive examples and holding employees accountable
for ethical conduct. ERC research has found that where management
displays more ERAs, misconduct is reduced, reporting increases and
pressure to commit misconduct is reduced.
Ms. Davidson,
along with special guests John
C. Lenzi, Chief Compliance Officer, Altria Corporate Services and
Michael Monts, VP Business Practices, United Technologies Corporation
(UTC), presented the
second webcast on "The Impact
of Leadership on Ethical Culture."
Mr. Lenzi discussed Altria's 2003 Compliance
Index, which is a set of items used to measure perceptions about
corporate ethical compliance. and their 2004 Compliance and Integrity
Survey on Culture. He said they found "Clearly having senior
management and immediate supervisors talk the talk AND
walk the walk has the most impact."
Mr. Monts talked about "Ethics
in Evaluating Employee Performance" at UTC, discussing their
"Business Practices Competency", which is tailored to
managers and considers to what extent the following behaviors are
displayed:
- Good communication (which covers
ethics)
- Modeling of ethical behavior
- Keeping commitments
- Maintaining accountability among
employees at all levels
- Visibly supporting Ombudsman (help-line)
and business practices (ethics and compliance) programs
- Upholding compliance mandates in
the face of competing pressure
The third webcast,
on "Measuring Ethical Culture," was presented by ERC Senior
Project Manager Skip Lowney,
along with David M. Mayer, Ph.D.,
Assistant Professor, Department of Management, College of Business
Administration, University of Central Florida, and Michael P. Campbell,
Chairman Employee Ethics Committee, Science Applications International
Corporation (SAIC).
Mr. Lowney reiterated that ethical
culture is the unwritten code of conduct by which employees learn
what they should think and do. The elements of ethical culture are
the identifiable beliefs and actions that comprise an ethical culture,
and which we can measure. These identifiable beliefs and actions
are termed Ethics-Related Actions (ERA's). He noted that ERC measures
eighteen ERA's within organizations; collects data on them through
the survey questions; and then creates an index from them.
Mr. Mayer discussed 10 tips for measuring
ethical culture, including:
- Decide which dimensions of ethical
culture you want to measure
- Decide which stakeholders you want
to focus on
- Decide whether you want to measure
"culture" and "climate"
- Make sure the level of analysis
is constant across scale items
- Avoid items high in social desirability
- Make sure questions focus on employees'
perceptions
- Before creating your measure know
your outcomes of interest
- Must appropriately match EC to outcomes
of interest
- Creating scale scores can improve
your validity and reliability
- It not only matters if EC scores
are high; agreement also matters
Mr. Campbell discussed his organization's
internal surveys, the organization's participation in ERC's industry
group surveys and benchmarking, along with the importance that empowering
employees -- through ownership, positive leadership and a sense
of participating -- has on developing the essential elements of
an ethically committed organizational culture.
Participant satisfaction was high for
ERC's first foray into online learning and more webcasts are being
developed for the upcoming year. Advance notice of new programs
will be announced in this newsletter and on the ERC website.
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**Why
Measure Ethical Effectiveness
One might ask "Why measure the
effectiveness of an ethics and compliance program?"
Charles Ruthford, Ethics Program Development,
The Boeing Company, and ERC Fellows Measurement Working Group leader,
says two reasons jump to mind: it's good business practice and the
Federal Sentencing Guidelines state "The organization shall
take reasonable steps - to evaluate periodically the effectiveness
of the organization's compliance and ethics program." In this
article, he also discusses two different categories for measurement:
process and outcome.
Read this article at:
http://www.ethics.org/resources/article_detail.cfm?ID=881
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**Is
Your Culture a Risk Factor?
"Culture is the leading risk factor
for compromising integrity and compliance in companies today,"
says this white paper by Working Values. "Yet many organizations
are unable to implement a truly effective ethics and compliance
program because they lack sufficient knowledge of how their culture
can create vulnerabilities and risks. And without that knowledge,
companies cannot measure progress towards meeting ethics and integrity
goals."
Read this white paper at:
http://www.workingvalues.com/Risk_WhitePaper.pdf
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**ERC
Launches "Donate Your Data" Program
Many organizations conduct regular
employee surveys to learn more about ethics, compliance, risk and
misconduct in the workplace. "While the data from these surveys
are useful for understanding the dynamics of an individual organization,
it also has tremendous potential to benefit the ethics industry
as a whole when merged with data from other organizations,"
said Dr. Patricia Harned, President of the Ethics Resource Center.
ERC's "Donate Your Data"
program allows organizations to donate ethics-and compliance-related
data, from current or past surveys, for use in ongoing research
on topics of key concern to business leaders. Data from entire surveys
or from individual questions (including ethics questions in HR surveys)
are of interest. Donated data will enrich the overall data set that
ERC uses to formulate thoughtful research pieces on topics that
are important to business leaders, such as ethical culture and the
effectiveness of training programs. Where the data has been collected
in a comparable manner, it will also enhance ERC's benchmarks for
ethics and compliance program effectiveness.
Read this press release at:
http://www.ethics.org/news/releases/nr_20060711_dyd.html
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News from the ERC
ERC Chair Stephen D. Potts Appointed
to Chair Johns Hopkins Review
Following a wave of public controversy
in April 2006 over a consulting relationship with an external company,
Johns Hopkins University leadership set in motion a review of institutional
policies and processes related to business relationships. "The
goal is to establish a clear, consistent, comprehensive, university-wide
set of principles and criteria for evaluating proposed relationships,
especially proposals that envision the use of the Johns Hopkins
name," said William R. Brody, president of The Johns Hopkins
University and Edward D. Miller, dean and CEO of Johns Hopkins Medicine
in a press release. The university asked ERC Chairman of the Board
Stephen D. Potts, former director of the U.S. Office of Government
Ethics, to lead this review.
Read the Johns Hopkins press release
at:
https://www.hopkinsmedicine.org/Press_releases/2006/Klinger.html
Recent Presentations by ERC Staff
Character Development Manager Rielle
Miller presented on "Ethics & Moral Choices" at the
first Non-Profit Leadership Summit hosted by the Council for Nonprofit
Innovation in Arlington, VA on May 16th
Ms. Miller and Character Development
Associate Lena Thomson presented on Academic Integrity and the work
of ERC's Character Education department to a group of Israeli Education
Ministry officials. sponsored by the State Department, on June 6
at ERC.
ERC President Patricia J Harned, Ph.D.,
and ERC Board Chair Stephen Potts participated in The Business Civic
Leadership Center (BCLC) 2006 Partnership Conference: Strengthening
Organizational Values and Stakeholder Trust. Dr. Harned moderated
a session on organizational development strategies. Mr. Potts was
part of a panel that discussed how business, nonprofits and government
agencies can work together to promote trust and integrity.
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Publications and Media Coverage
Theory & Practice / What Would
You Do? Ethics Courses Get Context, Wall Street Journal, June 12,
2006
As U.S. employers have bolstered workplace
ethics training in the wake of a rash of corporate scandals earlier
in the decade, says this article, they often deluged employees with
long lists of do's and don'ts. The article mentions the findings
of ERC's 2005 National Business Ethics Survey and quotes ERC President
Patricia Harned.
"Lots of companies are training,
but it's not really making a big difference," says president
of the Ethics Resource Center. Dr. Harned said much of the training
isn't "sophisticated" enough. Employers often rely too
much on one-size-fits-all ethics programs, instead of tailoring
programs to different types of workers at different levels of the
hierarchy, she says.
Read this article at:
http://www.careerjournal.com/columnists/theorypractice/20060616-theorypractice.html
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Offering Our Thanks
As a non-profit
organization, the Ethics Resource Center depends on contributions
from many generous donors. Without their dedication and trust, many
of the programs and projects highlighted in this newsletter would
not be possible.
ERC thanks
the following for recent contributions:
- Bristol Meyers Squibb Foundation
- Combined Federal Campaign
- Rich and Lesli Cohan
- DeLeon and Stang, CPAs
- Dr. John E. Fleming
- Goodyear Tire &
Rubber
- Shell
Oil Company
- Stephen D. Potts
- Working Values
We invite
you to join our loyal contributors in lending your support.
To find
out about how to support the ERC, go to:
http://www.ethics.org/support_how.html
The Ethics
Resource Center (ERC) is a non-profit, non-partisan educational
organization exempt from taxation under the Section 501(c)(3) of
the Internal Revenue Code. All gifts are tax-deductible to the fullest
extent of the law.
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