HR is not exclusively responsible for culture

According to a recent article in Forbes, one myth about corporate culture is that it is exclusively HR’s responsibility.

While it is true that how we hire and reward people does influence culture, every single process in an organization also plays a role. How we go to market is a process that can influence the culture of the entire organization. How a supervisor expects subordinates to respond to her Saturday morning texts immediately will affect that micro-culture.

Culture is an outcome of how we do things. Every negative aspect of a culture can be linked to a process, formal or informal, reduced to a policy or not. Identify and change that process, and you’ll change the culture.

We all can do this. We all must do this. HR cannot do it alone.

Wired to get along

In his book Brain Rules, John Medina explains how humans evolved to get along with each other.

Human babies cannot survive on their own for many years after birth and cannot reproduce for well over a decade, so adults need to survive long enough to see their children pass the genes on. For most of our existence, the only way for an adult to survive was to be part of a tribe large enough to provide food and protection to its members.

Only recently has it become possible for grownups to survive on their own. Still, without family and friends and colleagues, their quality of life is questionable. The technologies that have allowed humans to leave the tribe have evolved faster than our survival instincts. We still long to fit in, to be appreciated, to give, to have a tribe.

Perhaps evolution will eliminate this longing over the millenia. But for now, we can take comfort in the fact that we are wired to get along. As E&C professionals, we deal with more deviant behaviors than most, and that can distort of view of the world. It’s worth reminding ourselves that almost everyone we know is kind and eager to do the right thing, for their benefit and for the group’s. Let’s keep those beautiful souls in mind when we create our policies, training, controls and other programs.

The arc of the moral universe

This post was originally published on January 17, 2017.

A century before Martin Luther King’s “Where do we go from here?” speech of August 1967, Theodore Parker said the following:

I do not pretend to understand the moral universe; the arc is a long one, my eye reaches but little ways; I cannot calculate the curve and complete the figure by the experience of sight; I can divine it by conscience. And from what I see I am sure it bends towards justice.

The arc doesn’t bend on its own. The bend is created by the courageous and persistent work of a minority, who possesses a moral imagination capable of seeing a future world that is better than today’s.

And so do we all have a responsibility to see the injustice about us, and to work towards its elimination, even if we never enjoy the fruits of our labor.

You are not obliged to complete the work, but neither are you free to evade it. — Rabbi Tarfon

ECI Fellows Meeting – Day 2

[If you haven’t done so already, I recommend you read my notes on Day 1 first]

My biggest insight on Day 2 came when a colleague asked “When do you stop looking for the root cause of a problem? Because if you keep asking “why?”, you’ll always end up at the same place: a failure of leadership.”

Perhaps there is one more “why?” after this cause. Why did leadership act this way or failed to act appropriately? The answer will point at the organization’s culture. It will highlight “who they really are”. And since culture is an outcome of processes – of “how things are really done around here” – we can then identify the process that needs to be changed.

In essence, every root cause analysis effort should aim to answer “What is it about our culture that allowed this failure to happen? And what processes are generating this culture?”

If we address these processes, we can start changing the culture.

ECI Fellows Meeting – Day 1

The ECI Fellows are currently meeting to discuss root cause analysis (RCA) and how to apply it in the E&C function. Here are some of my notes from Day 1.

  • The first question on the most recent FCPA guidelines that the DOJ issued to help its US Attorneys determine if an organization should be prosecuted is whether a RCA was conducted.
  • Many organizations do not conduct RCA because they suffer from 4 common learning biases:
    • Success bias: We prefer success over failure. When we fail, we don’t want to spend time on our failure.
    • Action bias: We prefer to do rather than reflect. We are too busy to learn.
    • Fitting-in bias: When we join an organization, we believe it’s best if we just fit in, so we don’t challenge how things are done.
    • Expert bias: Rather than learn how best to do the work from those at the front lines, we tend to run to senior executives in the ivory tower or to external consultants.

To learn how to overcome these biases, see this HBR article from our presenter.

  • Effective RCA usually requires an executive champion in the organization.
  • 69% of legal violations resulting in public settlements between 2011 and 2013 can be attributed to cultural issues in the organization. Yet, most RCAs do not look at the cultural or behavioral aspects of the violations.
  • When defining your problem statement before the RCA exercise, make sure it follows the MECE principle: Mutually Exclusive, Collectively Exhaustive.

How good do you want to be?

Not everyone aspires to be an ethical leader.

Some simply want to do what is right, quietly, on their own. They are not looking to inspire others to do the same (although they might do that occasionally without intending to).

Others simply want to follow the rules. They believe that playing by the rules is playing fair. Whether the rules themselves are fair to all players is for someone else to decide.

A few believe that all is fair in love and war. They love their family and business is war. They have one life to live and they want what is best for their loved ones. If being loyal means that they need to break a few rules here and there, then so be it.

And perhaps all of us fall on different points of this spectrum at different times. Especially if we don’t give much thought to how good we want to be.

How about today? How good do you want to be?


Some organizations are known for their culture.

Uber, Zappos and Southwest quickly come to mind. And of course, Netflix, with it’s famous culture deck.

In a recent podcast, the author of the Netflix culture deck, Patty McCord, was asked to describe the best way to create (or fix) a corporate culture. Her answer was simple: model the behavior you want to see in others.

This simple tip is important for leaders who do the right thing (who behave like adults, as McCord would say) but who fail to be visible about it. Many ethical decisions are made within the C-suite and not shared with the rest of the organization. That is not a good example of “modeling”. We need these executives “on the runway”, flaunting their good behavior, if you’ll excuse the analogy.

This is where we, the ethics & compliance professionals, can come in. We are often close enough to our leadership to witness these commendable acts. We should document them and broadcast them for all to see, so that everyone understands what behavior is expected.

(For tips on branding, documenting and marketing, check out Seth Godin and Gary Vaynerchuk.)