Re-Framing Compliance to Motivate Employees

A few years back, I was required to complete sexual harassment training. Even as a female, I didn’t want to do the training because I was just so busy with other things. But it was required, so I did it. The video was informative and used scenarios to teach the laws that I should obey. But what was missing was the “why” — and by simply answering the “why” question, this training could have been very motivating to me as an employee.

As trained ethicist, I have no doubt that companies would benefit greatly by providing a values-based framework for their compliance training. Compliance shouldn’t just be about telling people “do this” and “don’t do that.” It needs to be set within a larger framework of ethics and corporate values.

One approach that could be very helpful would be that of Narrative Ethics. Narrative Continue reading

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How is Ethical Behavior Fostered in an Organization?

In my previous post, I argued that compliance programs in corporations are most effective if they employ a broader ethical/values-based framework. I want to further that argument from a different angle, using findings in cognitive-developmental psychology.

In the 1950s, Lawrence Kohlberg began a research project to determine how humans acquire the moral beliefs that shape their ethical behaviors. Based on his research he argued that there are three basic levels of moral reasoning: Preconventional, Conventional, and Postconventional.

Individuals who operate at the Pre-conventional Level, interpret the rules of social institutions egotistically: right behavior is whatever benefits me. One thinks of Bernard Madoff as an example of a Pre-conventional thinker who earned his wealth by disregarding Continue reading

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How to Teach Compliance

Biking the California desert

When I lived in Montana a few years back, I discovered a passion for mountain biking. After numerous spills and flips over the handle bars, a seasoned mountain biker gave me a most valuable piece of advice: look in the direction you want to go. If you focus on the single-track in front of you, he said, you’ll stay on the track. If you are constantly looking at the ruts, he warned, you’ll unconsciously swerve that direction and probably find yourself landing on your back, again.

Over time, I discovered that this advice doesn’t just apply to mountain biking. Research shows that it is perhaps THE key to mitigating risk in a corporate environment.

Companies can approach compliance in one of two ways. First, they can focus on preventing illegal activities, i.e. describing and avoiding the ruts. While I’ve not worked at Boeing, a simple glance at their code of conduct indicates that this approach may dominate their compliance programs. The first two points of their code warns against major ethical ruts that Boeing has fallen into in the past decade: don’t engage in activity that is a conflict of interest and don’t take advantage of your Boeing position for personal gain. Certainly, it is important to know where the ruts are located. And in such a highly regulated industry, Boeing has a major challenge in simply mitigating risk.

Yet risk mitigation is far more effective when the programs are informed by an ethical framework that is broader than legal compliance. Thus, we turn to our second approach: Continue reading

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Bartell Drugs

This morning, I attended a breakfast hosted by Kiros in which Jean Bartell Barber described her work as Vice President and Treasurer of Bartell Drugs. I was pleased to hear her discuss the ethics that drive company decisions, confirming that Bartell is one of the many companies in the Puget Sound that is seeking to build a company-wide culture that places a high value on people. Barber gave numerous examples of her own efforts to value people while also building a profitable company. For example, after an earthquake struck near the corporate headquarters and caused damage to warehouse and office building, her biggest concern was not losing profitability but keeping her people safe. Or when a pharmacist who had worked for the company for over twenty years made a human error by giving an elderly man the wrong Continue reading

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As a teenager sitting at the dinner table while my parents discussed the day, I heard the word again: Integrity. That little word held deep meaning for my father, the regional manager for an HVAC company, who found himself caught in continual battles with the manufacturer of their products. For years the manufacturer had refused to acknowledge defects in some of the machinery sold and distributed by my dad’s office.

As I listened to him describe the day’s battle, I remembered visiting his office months earlier as a call from an irate customer came through. I’d been sitting across from him at his desk, when our conversation was interrupted by a knock at the door. “Joe,” one of his salesmen said, “I’ve got Ron Walls on the phone. I think you’d better talk to him.”

“Sure, transfer him through.” His look told me to sit and wait quietly. The call came through and he picked up the phone, “Joe Smith, speaking.”

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How to Prevent Human Trafficking in Your Business

In June 2010, Kroger CEO David Dillon listened to a presentation at a shareholder meeting that no CEO wants to hear. According to the shareholder, “Sunripe,” a label of Pacific Tomato Growers and a supplier to Kroger has been known to use enslaved workers and has been accused of unjust working conditions. The shareholder argued that Kroger was implicated in this injustice because of its continued relationship with Pacific Tomato Growers. Dillon responded by referring to Kroger’s code of conduct, which explicitly prohibits use of forced labor, and he said that Kroger would work with growers on this issue.1 Perhaps because of Kroger’s efforts, Pacific Tomato Growers signed an agreement in October 2010 that set new standards for responsibility and accountability.2


While the problem of forced labor (or slavery) has existed throughout history, globalization has created new avenues for perpetrators to move and exploit vulnerable persons. The trafficking of human persons has actually been ranked as the second-most lucrative organized crime, up there with drug and arms trafficking. Many companies unknowingly profit from forced labor, often because the crime is hidden and difficult to detect. In this blog post, I will define “human trafficking” and provide a process for companies to avoid profiting from this devastating crime.

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Models of Corporate Social Responsibility Part 4 (of 4): Social Activism

John Rawls

Finally, the fourth model of Corporate Social Responsibility can be called the Social Activist Model.1 Much like the Social Demandingness model, this model assumes that corporations are responsible to the whole of society. Proponents of both of these models argue that executives should be social and moral leaders in the community and that corporations should be addressing major issues like poverty and global health.2 Unlike the Social Demandingness theory, however, the social activism (or moralism) model assumes that there is a universal standard for determining these responsibilities. Many theorists (like John Rawls) argue that the basis for this standard is ethical while others argue for a religious basis. Yet others (such as Gewirth) argue that the basis for such a standard is grounded metaphysically, in aspects of human nature.

What sort of responsibilities do these theorists advocate? There are a wide variety but here are a few responsibilities:3 Continue reading

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