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

The Office and culture of non-compliance

The Office is a very popular US television comedy series, based on a UK series of the same name. It follows the daily lives of the employees working in the Scranton branch office of a paper company. Filmed as a “mockumentary,” to imitate the style of a documentary, the show features many “interviews” with the employees and management. While it does address things in their private lives and personal relationships between the characters, most of the action of the show occurs in the workplace and is based around the dynamic of the characters as colleagues and employees.

In this light, the show offers many interesting insights and tropes about the experiences of working in a small or branch office, with an eccentric boss and idiosyncratic colleagues, dealing with policies from head office and the challenges of working together effectively. Scenarios relevant to compliance are touched upon often in the series, frequently showing examples of very poor management practices or problematic cultural values.

  • “Sexual Harassment” (Season 2, Episode 2): In this episode, the office’s HR personnel are providing sexual harassment refresher training and reviewing policies after an incident at corporate headquarters. Instead of setting a tone at the top to reinforce how important a respectful and safe working environment should be, and how inappropriate harassing behavior of any kind is, the manager Michael Scott has a tantrum and makes light of the importance of the policies. He never embraces his duty as a leader to model positive behavior; even when he defends one of his staff against the rude joke of another, it is accompanied by an improper comment of his own, as he misses the opportunity to step up and reinforce a culture of compliance.

 

  • “WUPHF.com” (Season 7, Episode 9): In the cold open of this episode, the power goes out in the office and the server goes down. Instead of having reliable disaster recovery procedures on hand or a controls framework that would enable business continuity in this sort of situation, the staff must resort to guessing the password as a group. Obviously this is not advisable in light of critical cybersecurity concerns which face all businesses today, especially small offices such as this one which might be assumed to have weaker controls and be targeted by intruders hoping to gain access to the larger company network.

 

Actually, the “WUPHF.com” episode, in its entirety, is another good example of poor compliance practices. Ryan Howard, with Michael’s encouragement and financial backing, claims that he has devised a web-based messaging system called WUPHF.com. In reality, Ryan is committing a fraud, in that the website does not function (despite his attempts to advertise to the contrary) and the only purpose for it is to try to sell off the domain name. Instead of uncovering and disclosing this fraud, and protecting the other investors, Michael backs Ryan. Though he later withdraws his support for Ryan, the fraud is allowed to continue because Michael does not step up and see beyond the conflict of interest posed by his personal relationship with Ryan in order to act on behalf of the investors as he could do.

 

  • Scott’s Tots (Season 6, Episode 12): In surely one of the more cringe-worthy moments for Michael Scott – that’s saying a lot – he fails to keep the promise he made years before to pay college tuition for a group of lower-income children. Upon their high school graduation, he must confess that he has not upheld the duty to them that he created with his promise. Instead, he apologies and tries to give them batteries as a conciliatory gesture. Apart from the terrible awkwardness of the concept itself (this episode aired in December 2009, deep within the global financial crisis, an uncomfortable time to try to address financial fraud humorously), it’s unfortunate, and a sign of weak leadership, that Michael doesn’t seem to acknowledge at all the reliance upon his integrity he created by making that commitment.

 

  • The Incentive (Season 8, Episode 2): In the absence of Michael Scott, his former employee and now new office branch manager Andy Bernard is proving that the apple doesn’t fall far from the tree when it comes to insufficiently ethical leadership. Andy finds himself at a loss for how to motivate his employees and decides to create a points-based incentive system to encourage their performance. Rather than appealing to their values or accepting lower performance in exchange for more sustainable and strategic efforts, Andy chooses a management method which will yield only short-term, temporary improvement or engagement.

From the above it is abundantly clear that The Office does not depict a corporate culture of compliance or a values-based approach to business strategy. Rather, it shows a company that is run, at least in the Scranton branch, with an ethos of non-compliance in the workplace.

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