Perspectives of Chief Ethics and Compliance Officers on the Detection and Prevention of Corporate Misdeeds: What the Policy Community Should Know

By Michael D. Greenberg | Go to book overview

4. CORPORATE CULTURE AND ETHICS — CONSIDERATIONS FOR
BOARDS AND POLICYMAKERS

OVERVIEW
Participants in the final session of the conference focused more deeply on the topics of corporate culture and ethics, their relationship to formal C&E initiatives, and considerations for boards and policymakers in trying to promote strong ethical culture within organizations. Much of the discussion during this session focused on whistleblowing, and on the importance of an “open-communication” culture that encourages employees to raise concerns, and report instances of malfeasance or misconduct to management. Whistleblowing presents a challenging set of practical and cultural issues for corporations to manage. On the practical side, these issues include implementing controls and mechanisms to support and protect workers who come forward as whistleblowers, while on the cultural side, the issues extend to creating an environment of trust and non-retaliation in which people feel comfortable with coming forward to disclose, even when this involves reporting misconduct committed by peers or superiors. Complementing the conference discussion about whistleblowing, this session also touched on a range of other issues connected with organizational culture and ethics, such as the formal definition of corporate culture, the return on investment (ROI) argument in support of C&E activity, and the challenges involved in pressing the corporate community to take both C&E, and the development of ethical culture within organizations, more seriously.Several of the major points of discussion and agreement during the session included the following:
Whistleblowing and open employee communication are critical resources for detecting fraud within companies.
Anti-retaliation mechanisms are focal to efforts to protect whistleblowers within companies, and by extension, to encourage them to come forward.
Anti-retaliation ties directly to organizational culture, and to norms about trust, honesty, and open communication.
“Corporate culture” corresponds to a series of intangibles, including expectations for workers, ways of doing business, internal and external reputation, and other factors not captured by written policy.
An ROI argument for C&E (and for ethical culture) is challenging to make, with the result that C&E may more often be viewed by management as a cost center, rather than a revenue center.
CEO endorsement of ethics as an overriding priority in an organization (or an industry) may sometimes help to drive top-down changes in culture and values.

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