Maximizing Integrity at Key Career Moments

In working with more than 450 chief compliance and ethics officers around the world, we see that leading programs effectively foster the conditions – the culture – that drive employee adherence with all laws, regulations, and company standards.

This mission is hard and faces many daily challenges, including aggressive growth targets, changing operating processes, cultural differences, unpredictable behaviors, and a natural employee resistance to change.  Frequent (and recent) corporate compliance scandals attest to these challenges.

Most compliance programs have less than five hours of employees’ time each year for dedicated compliance and ethics training (or barely a minute per day).  So, how do we shape employee behavior while allowing for the strategic freedom, entrepreneurial spirit, and on-the-job innovation that drive corporate success?

We’ve Been Asking the Wrong Question:  It’s not What, It’s When

To create the right conditions, compliance and ethics officers currently create a variety of policies, trainings, controls, incentives, and the like.  Some of this effort is required, and much is helpful.

But if we really want to drive the right behaviors, we should not start by asking what activities and inputs (policies, training, etc.) we provide.  Instead, we should ask when and how we can most inflect employee behavior.

Corporate Change and the Career Moments that Matter

In the past two years, 84% of companies experienced a significant company-wide change. Macroeconomic uncertainty, advances in technology, a changing globalized workforce, and many other factors seem likely to accelerate this already rapid pace of corporate change. For compliance and ethics officers, this frequent change presents an underappreciated risk – ‘change risk’ – and a significant opportunity.

To understand how employees experience corporate change, the CELC launched an exhaustive employee survey. The survey tested 16 career moments to understand their specific impact on employee misconduct, reporting, engagement, and receptivity to training and communications.

CELC’s research finds that specific career moments represent key times when established patterns of employee behavior are disrupted and subject to change.  A failure to respond effectively at a career moment leads to significantly higher rates of misconduct while an effective response can improve employee behaviors and productivity.   Career moments represent the times when compliance and ethics can have maximum impact on future employee behavior.

• Frequent Change is the Rule of the Day—On average, employees experience 2.2 significant career moments per year.  In fact, 83% of employees experience a significant career moment (corporate changes, compensation changes, promotions and role changes) in a given year.
• Regular Change Doubles Misconduct—Career moments have significant implications on employee behavior, impacting everything from misconduct rates to retention to productivity.  In fact, employees experiencing two career moments in a given year observe twice-as-much misconduct as other employees.
• Change Drives Risk—Specific types of change significantly impact compliance risk. For instance, employees experiencing a corporate layoff observe 3x as much bribery, 3.5x as much insider fraud, and 4x as much insider trading as unaffected employees.
• All Is Not Lost—Compliance and ethics can substantially mitigate the impact of key career moments on observations of misconduct and perceptions of integrity. But, the current peanut butter approach (i.e., spread a little outreach everywhere) underperforms.
• The Ideal Intervention—Taking a career moments-based approach can improve employee perceptions of integrity by 40%, reduce observed misconduct by almost 67%, and increase employee engagement by 23%. In fact, an “ideal” intervention can actually improve employee perceptions of integrity above their pre-moment level.
• Right Time, Right Channel, and Right Message—CELC’s research helps companies target the right employees with the right message at the most critical times. Companies can now specifically target employee messages for maximum impact.

 

A Better Way Forward:  The Career Moments-Based Approach

A single hour spent with employees during a key career moment has a demonstrable impact on employee misconduct, reporting, and engagement—well beyond the measured impact of online compliance and ethics training.  This insight – better returns from training and communications targeted to moments of heightened receptivity – is critical for reducing compliance risks and advancing corporate compliance and ethics.

Leading companies are already building compliance systems more responsive to career moments. Strong functional partnerships and effective use of technology allow compliance and ethics officers to move from standard (and often expensive) compliance training that is “customized to company” to a more cost-effective, “mass customization” approach.

Importantly, the focus is not on building ever more elaborate learning management systems but instead on building internal capabilities for real-time response to moments.

Call to Action – “Monday Morning To-Do’s”

• Build Plans that Drive Results.  Schedule time with HR and line management to share benefits of communicating with employees before key career moments with messages about integrity and organizational justice. Use the Compliance and Ethics Manager Portalto prepare for these “Monday morning” conversations.
  • Identify a communication plan to target moments across the company
  • Use CELC templates to craft communications that can be delivered by HR, Communications, and line management
  • Use CELC tools and guidance to prepare line management for one-on-one staff conversations or staff briefings

• Minimize Exposure to Risk.  Understand the compliance and ethics risks of specific corporate changes.  Collect data across your employee populations (e.g., business units, divisions, position levels, etc.) using our tools and diagnostics such as compliance risk assessments or employee culture surveys.

• Save Time and Money.  Deliver targeted outreach before and during employee onboarding to impart a commitment to integrity before negative behaviors set in.  Leverage best practices from leading companies to Create Compelling Compliance and Ethics Training and use the Compliance and Ethics Message Generator to craft powerful compliance and ethics messages and target communications by employee segment, topic area, and type of message.

• If you are not a current member and would like to learn more please visit the Career Moments webpage.