A simple process to ethical leadership

I define ethical leadership as having the skills to execute ethical decisions in ways that inspire others to become ethical leaders.

If you are new at ethical leadership, here’s a practical approach to get you going:

  • On a sheet of paper, create a table with 4 columns.
  • In the first column, write a list of initiatives you are working on. Write each initiatives in a separate row. Take a week or so to do that. Just write the initiatives as you work on them.
  • In the second column, write one (or more) ethical dilemma associated with each initiative. The dilemmas may not be immediately obvious. Take your time. Just revisit the list every day.
  • In the third column, write the decisions you made to resolve the dilemmas. Don’t hesitate to ask for help. Involving the right people lead to better decisions.
  • In the fourth column, write how you will execute each decision in a way that will make you visible and vocal about the importance you place on ethics and compliance.
  • Keep doing this until it becomes second nature.

The second column develops your ethical awareness.

The third column develops your ethical decision-making.

The fourth column develops your ethical leadership.

There you have it. A simple process to ethical leadership. Give it a go and, if it works for you, share it with others.

Pause, if you can


Today is a work holiday in the U.S.

Some people will work anyway.

Some because they love what they do and want to do it.

Some because their services are essential, like emergency responders.

Some because they have no real choice, like those working for a national chain who decided that the extra revenue is worth paying overtime and denying family time (see this chain for a better philosophy).

Some because they think they are expected to work and will be rewarded for it, even though their organization is officially closed for the day. This  speaks to the culture of the organization, or “how things are really done around here.” It matters not what the policy says; employees know what the real rule is.

If we work in an organization that is officially closed today and still receive a call or an email from a subordinate, one that could have waited a day, we must pause and ask “what is it about us that makes our people think they have to work on a holiday?” And let’s not be too quick to blame the subordinate, to deflect responsibility. At the very least, we can do a few things:

  • Tell our subordinate that she should enjoy the day off, relax, recharge, and return to work with new energy
  • Follow up with her in the coming days to assess her workload
  • On the eve of the next holiday, set clear expectation of rest for your team. A short email thanking them for their work and wishing them a nice break can go a long way in creating the right culture.


This post was originally published on 24 November 2016.

Fixing the (w)hole

Ethics & Compliance Officers are often required to conduct internal investigations. Most of us are not professional investigators and the process can be overwhelming and intimidating at first. If you are still new at investigations, you should read Jeffrey Klink’s excellent post on the basic 7 steps to follow.

The last step, case evaluation, is of particular interest to me. This is when the business leaders (not the investigators) are supposed to “fix the holes that allowed the misconduct to occur.” For too many leaders, this process involves adding controls or policies to the existing framework. In other words, each time the pipeline is leaking they put some duct tape on the hole. Meanwhile, no one is addressing the fact that perhaps the water pressure is too high.

Here is a question I like to ask myself at the end of an investigation: “What is it about our culture that made our employee think it was OK to do this, or that he would get away with it?” This is a critical question if you believe, as I do, that culture is an outcome of your processes. If you identify the process that created the culture that lead to the misconduct, you can work on the cause of the leak. You’re fixing the hole, and then some.

Is there an element of your culture you don’t like? Find the related process.

Hi! I’m calling to thank you!

I have 5 meetings scheduled for today.

It may seem like a lot but 4 of them are calls that won’t exceed 15 minutes.

The first and fourth calls are with new ethics & compliance officers on my team. One from Thailand (at 6:30 AM my time, about 20 minutes from posting this) and one from the US. There are 3 levels of management between these two colleagues and me, but I want them to know they can also count on me for support.

The second and third calls are with ECOs celebrating their 1st (Canada) and 7th (Italy) anniversary with our group. They are as enthusiastic about their job today as they were the day they started, and I want to recognize that.

There are 500 ECOs in my company. I try to connect with everyone at least once per year by phone or in person. Not easy. But oh so worth it. I get to hear what it’s like to join our group, to be on the front lines of ethics & compliance, to operate far from the mothership, to implement a program based on values that may be different from the local culture.

This is the team that brings to life the dreams we dream of at the corporate office.

I want them to know I am grateful.

Systems and scandals

Today I want to share one of the smartest interviews I’ve read about corporate culture. Amy Conway-Hatcher knows her stuff. You might want to read it before continuing.

Allow me to add my two cents to the question about the role of culture in enabling scandals. The interviewer suggests that scandals happen despite the systems and policies that most major institutions have in place. I argue that these scandals happens because of the systems and policies in place.

While the interviewer was most likely alluding to standard policies like non-retaliation,  harassment, and keeping accurate records, which are all good and necessary, we must also consider the less formal systems that grow in organizations. Take the Wells Fargo “system”, for example. Start with a CEO that shouts “Eight is Great!” all the time, tolerate the managers who then decide to micro-manage their sales people to make sure 8 new accounts are opened every day, allow HR to fire those who don’t meet the target, ignore that your have terminated over 5,000 employees for creating fake accounts in 5 years, and you get a scandal.

Surprising? Not a bit. And we could repeat the exercise with Volkswagen, Uber, Fox, etc.

A scandal is growing in your organization right now. Do you know what system to blame?


Sweet change

If you don’t know about Japan’s giri choco tradition, it’s worth looking it up.

In a surprising move on February 1, Godiva took a full page add in a leading Japanese newspaper and told women they should stop feeling obligated to offer chocolate to their male coworkers on Valentine’s Day.

This could very well be a marketing ploy on the part of Godiva. After all, no one buys Godiva chocolates for giri choco — they are simply too expensive. But let’s leave our cynicism at the door for a minute. Ever since the Weinstein scandal, we have seen a shift. People all over the world are speaking up loudly against gender-based practices that are imposed by one gender over the other (usually male over female). There is a real sense that we’ve had enough, that sexual discrimination and harassment can no longer be tolerated.

So perhaps Godiva is trying to boost sales by hacking the culture, joining the ranks of several companies with similar messages embedded in their recent Super Bowl ads. If that’s the case, we can still rejoice. These marketing giants really do their homework before spending their billions and, to me, these ads suggest that the cultural shift we are seeing is real and here to stay.

And that is sweet!