Compliance Culture

Practical insights for compliance and ethics professionals and commentary on the intersection of compliance and culture.

Compliance and ethics in Groundhog Day

Groundhog Day is a classic comedy film from 1993.  The movie centers around Bill Murray’s character Phil Connors, who is a weatherman on-location in Punxsutawney, Pennsylvania covering the annual Groundhog Day event there.  The town’s festivities around the ritual of the groundhog coming out of his hole to check whether or not he sees his shadow are a huge media event and popular celebration which Connors, who is generally obnoxious and condescending, finds ridiculous.  On February 2, Connors has an unpleasant and miserable day in which he is annoyed by everyone around him, acts out, and totally fails to charm his producer Rita Hanson, played by Andie McDowell, with whom he is in unrequited love.  The next day he wakes up and is alarmed and confused to find that it is not a new day and February 3, but rather it is February 2 again and the prior day is repeating exactly as it happened before.

Connors winds up trapped in a time loop in which only he is lucid of it.  He experiences February 2 over and over, with his memory and knowledge retained but otherwise no evidence in the world or other people that the day has happened before and will happen again.  Connors goes through a complicated process of reckoning with this reality and ultimately makes an ambition of getting Hanson, who hates him, to fall in love with him.

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Selected TED/TEDx talks on integrity

Integrity as both a personal and an organizational value is one of the central and recurring themes of this blog. Promoting and supporting integrity in individuals as well as in the groups in which they live and work is essential to encouraging cultures of compliance and ethical decision-making. Indeed, the foundation of the moral conduct people wish to see in each other and in their institutions in order to enhance the stature of truth and honesty in today’s complicated, interconnected world starts with placing personal emphasis on integrity and character ethic. With a strong and well-articulated individual commitment to moral engagement, people can purposefully contribute to the integrity of the communities in which they live, the groups in which they gather, and the organizations in which they work.

  • Aligning integrity with identity (Lester Tanaka) – Commitment to any character ethic value must be authentic. A person cannot decide to have integrity without actually embracing the honesty, judgment, fairness, transparency, and credibility that goes along with possessing this trait. Claiming to have it, without actually genuinely imbedding it, goes against the grain of the entire concept of integrity itself. Therefore individuals must, as Lester Tanaka suggests, make concrete and meaningful for themselves the interrelationship between the mental and the moral. A person’s identity should be aligned with and connected to the value of integrity and their intention to live with it. Therefore, all the other traits for which an individual has an affinity should be consistent with the goal of integrity. Self-examination and self-reflection will be both necessary to identify these corresponding characteristics as well as important for thoughtful and organic personal integrity.

 

 

  • Integrity as a currency for leadership (Barth Nnaji) – Integrity is also a core value for leadership. When faced with opposition or adversity, challenge or doubt, ethical leaders can always rely upon their integrity to represent themselves as credible, rise above the fray, and maintain a firm grip on ethical standards for decision-making and conduct. One of the differences between a manager and an ethical leader is, in fact, this commitment to their sense of integrity and the feeling of a strong responsibility to resist negative temptation or becoming overwhelmed by the magnitude of their tasks. True leaders stick to their own values and indeed promote their own integrity as the “currency” needed to get things done in collaboration with other people and organizations. Leaders who consider their reputations as one of their main assets would seek to protect the way they are seen by others by staying true to the expectations for their credibility and reliability. This way, people who lead with integrity become people with whom others wish to be associated, compared, and involved.

 

 

  • Building integrity – keeping promises (Erick Rainey) – Establishing integrity does not have to be an academic or theoretical challenge with abstract and lofty metrics by which its success is measured. Having integrity is as simple as keeping promises. Walking the walk, taking responsibility, and following through are simple but incredibly impactful actions which, when repeated, establish a pattern of integrity and worthiness of trust and reliance. This goes for individuals as well as for organizations. Delivering on commitments or being honest and transparent about it when it’s not possible to do so puts the value of integrity into powerful action.

 

 

  • Integrity and authenticity don’t make you trustworthy (Struan Robertson) – As noted in this earlier post, expectations for and ideas about trust, honesty, and the truth are all being transformed by today’s digital society. Shifting moral evaluations and perceptions of what is or is not true too often promote a convincing and compelling brand of dishonesty over difficult or complicated truth. In this environment there are many complex factors against true credibility and integrity. Simply appearing to be “good” or wanting to identify others as “evil” is not sufficient. Being relied upon is also not the same as being trusted or trustworthy.   As discussed above, commitment to integrity has to be both authentic and practical. An individual and all the individuals which make up organizations have to have an organic, real commitment to integrity in order to truly act with it, rather than to just pretend or attempt at it.

 

  • Integrity and the Life of the Planet (Zale Zeviar) – Apart from the integrity of individuals in both private life and the work place, corporate integrity is so important in society’s attempts to solve huge challenges, such as making environmentally-friendly consumer choices. The transparency and openness that acting with integrity and moral certitude can bring is also applicable to business core values. Accountability for earth-friendly business practices and products is just one expression of corporate social responsibility that exhibits business integrity. Small changes by consumers can be enabled by community and business values which can help the whole system to aspire to a higher level of integrity. This “corporate consciousness” is an active expression of integrity that spreads, aligning all the players in the chain universally around integrity as the common theme.

As shown above, defining integrity as a core value in all areas of life – self-identification, leadership, relationships with others, community engagement, social responsibility – is a powerful, purpose-driven approach. A commitment to recognizing integrity as a virtue and using a strong internal sense of its importance for one’s personal moral code enables individuals to be credible and responsible and to model these values to each other. With time, institutions and organizations will reflect the integrity promoted by the individuals within them, elevating the ethical register of society.

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The changing nature of, and expectations for, trust

Discussions of trust and honesty are popping up everywhere in the public discourse. From disputes over what constitutes “fake news” to discussions involving “alternative facts,” the current culture is obsessed with the struggle to determine what’s really real. Who can be believed, and why? How does anyone know for sure? The objective of establishing trust in an environment where the goalpost of the truth seems to be constantly in motion is challenging and even frustrating. However, in such an atmosphere, a flight to quality for integrity in ethical character and decision-making is needed more than ever.

  • The ubiquity of the internet makes it a powerful force in the overall assessment of trust in society. Concerns about security and privacy are a constant in the remote digital interactions of the internet, where much can be done and said anonymously. Advancements in technology promise to embed the internet and its connections further into the daily experiences of individuals and organizations. But does the internet hurt or help trust? At the very least, it seems that the nature of trust will be seen as evermore fluid, as the internet empowers the world yet suffers from countless security insufficiencies that set credibility and honesty on edge:  The Fate of Online Trust in the Next Decade
  • Compliance programs that are overly rules-based, focusing on preventing behavior defined as criminal or illegal and fine-tuned by enforcement standards, may prove inadequate for restoring trust in institutions. The public does not want to see that unethical behavior is only a problem if it involves breaking an existing rule or law. Indeed, a huge part of the compliance discipline is the aspirational aspect, where the controls seek to address the discrepancy that can exist between what is legal and what an organization wants to consider acceptable. Rather than going heavy on the rules-based approach, a values-based approach can be much more meaningful, giving the reassurance that the compliance program seeks to identify root causes and inspire ethical conduct, rather than just enforce rules and protect management from liability:  ‘Criminalized’ compliance may backfire in quest for better Wall Street cultures
  • Ten years on from the start of the global financial crisis in 2008, many observers are left underwhelmed by assessing the true change that has happened in its aftermath. Fundamental shifts in conduct and business practices were needed to truly reform the financial services sector and make the supervisory efforts over it effective. A major challenge in the recovery from the crisis was how to make the system more resilient, to withstand another crisis the same as or worse than before. However, perhaps more important was the effort to restore public trust in the industry, which could only be accomplished by taking a deep dive into the causes of the crisis and doing hard work across many organizations to address the reasons why and why not forever. While the regulators have made lots of new rules, and banks have been publicly shamed and put through the rigors of new testing and requirements that are seemingly without end, the markets don’t seem to trust that anything has really changed for the better – and maybe the public shouldn’t believe it either:  Markets Don’t Trust Banks, and They’re Right
  • So how to restore that public trust which has been violated and lost? Stronger governance is the first step, to weed out the problems which still exist and will take time to address effectively, like corruption, cybersecurity, and differences in reporting regimes. Injecting clarity into a truly integrated system which is more consistent and allows for comprehensive monitoring will help also to let the public know that supervisors are looking in the right places. These system overhauls and others should help to create markets and networks which are more likely to foster and support financial stability in the future:  Ten Powerful Actions To Restore Public Trust And Confidence In The Global Economy
  • As the advancements of technology constantly outpace regulatory and legal frameworks intended to control them, what implications do biometrics innovations have for trust? Data privacy concerns prevent many people from engaging in newer technologies, but what will happen when traditional authentication of identity is no longer available? Social media, AI such as facial recognition, and other advanced means of identification and verification are on their way, and all the problems of inclusion, access, and security that challenge their trustworthiness are coming with them:  The evolution of identity: trust, inclusivity, biometrics and beyond

Organizations must grapple with the fluid nature of trust and the expectations around it, in order to have any hope of inspiring trust and faith as cultural norms both inside and outside the office.

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Selected lectures on honesty and trust

Honesty in life is the foundation for integrity in business. People with a strong personal sense of correctness will be loath to discard their internal moral register easily just because they are in the workplace. Those who respect the truth, however challenging standing by that may become, and wish to be rewarded for it with being seen as trustworthy, are responsible stewards for organizational and individual values. The impact of a corporate culture that venerates honesty and trust is far-reaching into decision-making, business strategy, sustainability, and co-working.

  • The Growing Inequality of Trust (Richard Edelman) – One of the great challenges to establishing and maintaining trust in society today is the “trust disparity” – the difference between the portion of the public that is credibly informed and the population in general. This is a growing and far-reaching challenge to giving and getting trust, when people cannot agree on a view of the facts or are so predisposed toward mistrust. The contextual motivation for good corporate citizens to model integrity and impact societal change for the good is very strong, especially as trust is on the decline. CEOs and other business leaders should answer this call and leverage their honesty and unwavering commitment to tell the truth and disclaim misleading or false information.

 

  • What’s trust got to do with it? (David Horsager) – Lacking credibility will cost you. Trusted leaders and organizations are more successful, agile, and prepared for long-term survival. Establishing trust be the best motivation and the most effective marketing. The positive impact on business and life of trust should be underestimated. Trusting someone is a choice with benefits and consequences, and supporting trustworthy people to succeed can make a real change in our communities and organizations.

 

  • The behaviour of trust in the workplace (Jacqueline Oliveira) – Intercultural communication is one of the great challenges of the modern workplace. Global teams and international leaders have to reach across the norms of their home culture to find a way to relate to each other that can be understood by everyone but still meaningful and productive. Trust is a universal value which can create that connection for everyone to build upon.

 

  • Whom Can We Trust? (Richard Edelman, David Leonhardt, Tom Wilson) – Public perceptions of trust are on a sustained decline all over the world. What can individuals and their organizations do about it? Are we just doomed to a faithless future? If we can’t trust any of our institutions, how can we trust the people who work at them or, eventually, each other? The potential for moral decline in our private lives is precipitated by the deteriorating credibility of the organizations that dominate our news and the public attention. Personal leadership that is values-based and emphasizes the truth and trustworthiness over all other character traits is one possible path forward. If society starts to reward and appreciate people for their honesty and their eagerness to earn trust, then the public measures of success and expectations on businesses will follow in kind.

 

  • The Value of Trust (Dan Ariely) – How does trust impact decision-making and individuals’ perceptions of their own interests? The value is likely significant, especially insofar as many decisions are made and promises are kept or broken for practical, emotional, or even irrational reasons. Trust in themselves as well as in others does more to determine how people actually behave than their intentions.

 

Check back next week for the follow-up to this collection: selected lectures on dishonesty and mistrust.

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