Programs and culture

When the Ethics & Compliance Initiative (ECI) published the findings of its 2007 National Business Ethics Survey, it identified two drivers reducing ethical risks in organizations: a well-implemented program and a strong ethical culture.

Ten years later, I regularly meet with colleagues working in large national or multinational organizations that do not have an enterprise risk management (ERM) process in place. When I ask them how they identify risks, I get blank stares. “How do you decide what training to provide, what processes to put in place, what controls to enhance?” More blank stares. ERM is the foundation, the starting point of any well-implemented program.

ECI was clear in 2007: a strong ethical culture has a greater influence on reducing risk only when we have a well-implemented program in place.

With the news full of corporate scandals pointing to a bad culture, we all want to work on improving our culture. But perhaps it’s time we go back to basics and work on our programs.

Culture is an outcome of our processes.

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