An Effective Ethics Program: It’s Really Not About You

Recently a colleague at another organization had sought my input regarding her plan to initiate a formal ethics program. Pam’s organization had grown both organically and through acquisition, and with it new and more delicate issues had arisen. As its senior human resource executive, she had begun to sense that the burgeoning and increasingly diverse employee population could no longer simply rely upon an employee handbook and online training modules to guide day-to-day ethical decision-making.

Pam had done her homework. She understood the basis for developing a comprehensive Code of Conduct; establishing a Fraud & Ethics Hotline; and senior leadership setting the “tone from the top.” But where Pam got stuck was identifying the individual who would lead the Ethics Program and provide its “face” and its “voice”.

We delved into the importance of objectivity and consistency in all program activities and all communication issuing forth from the Ethics Officer. Pam recognized that such communication will range from informal dialogue to formal drafted opinions. We weighed the advantages and disadvantages of various professional backgrounds from which she could draw forth a qualified individual. Successful Ethics Programs  have been led by professionals with backgrounds as diverse as Legal, Internal Audit, Human Resources, Technology, Education, and Theology.

We agreed that the common thread of objectivity must prevail. An effective ethics leader is neither solely an advocate for the employee nor for the organization, but is instead an advocate for the shared values embodied in the organization’s Code of Conduct and associated policies. Thus, an ethics leader doesn’t bring his/her own personal opinions, viewpoints, morals, or theology to bear when reviewing a matter, but instead adheres to the organization’s documented guidelines.

Quite frankly, when an ethics leader acts in accordance with the organization’s culture of shared values, he/she will occasionally have to issue a formal opinion that will contrast with his/her own personal opinion. The outcome is about the good of the organization—not about personal preference or moral judgment. It’s not about you.

Over the course of time, this consistently objective approach will result in a library of ethics opinions that will provide predictability and precedent for leaders, employees, and successor ethics leaders to rely upon. Employee trust in the impartiality of the program will accrue through this neutral approach, further strengthening the organization’s culture of compliance.

And with that, Pam set off to recruit the ethics leader that would best represent her organization.