Let’s cut to the chase... it’s all about the behavior! Despite what you may have read or been told, business ethics and compliance programs are not about codes of conduct, policies, rules and mission or value statements. Don’t get me wrong, those certainly are important parts of any program, but those alone won’t guide a person’s behavior. What you say to employees is not nearly as important as what they see. Behavior, as we all know, is believable. In any organization, a manager’s behavior raises or lowers the bar for all who see it.
I recently talked to a colleague that had been appointed Vice President, Ethics and Compliance Officer for a medical device manufacturing company several years ago. Being a highly regulated company, they already had in place what most considered to be a very robust regulatory compliance effort. They augmented that program with a business ethics and compliance program that followed the seven elements in the Federal Sentencing Guidelines. But the most important thing that they did was set a behavioral standard for their managers. It was made very clear at the onset that one breach of their commitment to regulatory compliance and ethical conduct by any one of them would tank their efforts. They had to be the embodiment of their program. Their actions would speak louder than any words, but only time would tell if they were credible or not.
Within a few hours, they had all the information. The day shift group leader had stocked the production line for the Saturday morning production run with parts which had not been quality checked according to their very detailed and required processes. Fortunately, none of the product had been shipped.
The employee was called and asked to tell his side of the story. As he told it, he had a date that evening and was running a bit late. The parts had never failed the quality check in years so he just figured that “this one time” they would be fine. After listening to what he had to say, he was told to take the rest of day off, with pay, and think about what he did, how that aligned with what the organization stood for and what consequences, if any, should he receive for his actions.
When he returned to work the next day, he said, “You have to fire me.” When asked why he came to that decision?” He replied “I’ve watched you and the managers here. And you are who you say you are. This company stands for quality and we have to have a product that is safe for the patients who use it. What I did violated everything we believe in. If you let me stay, then you are telling everyone that it’s all lip service—that what you say about doing things the right way doesn’t mean anything. No one will ever believe you or anyone here again.”
He was right. He resigned.
It’s a lesson for all of us. While codes, policies, and value statements are a critical part of setting organizational standards, we should never lose sight of the fact that every day managers are being watched by their employees. The credibility of any business conduct and compliance program rests on their behavior. And it’s not just the “big” actions, it’s the little things that they say and do. I guarantee it—they are watching. The question for you is, are you comfortable with what they’re seeing?