Turn Culture Into Competitive Advantage
|
|
- Melinda Bennett
- 9 years ago
- Views:
Transcription
1 6 Baltzer Science Publishers Turn Culture Into Competitive Advantage Lessons from recent risk management failures Leslie Altizer* This article discusses CEB s research, lessons learned, and what organizations can do to prevent misconduct and compliance issues, and improve culture. It is now well understood, in boardrooms and beyond, that ethics and compliance lapses can be very costly. During the past two years, there have been several multi-million dollar penalties related to the U.S. Foreign Corrupt Practices Act alone. Quite a few of these penalties have been the result of lapses within the Life Sciences and Pharmaceutical industry. When you add in the costs of harassment, discrimination, conflicts of interest, fraud, records mismanagement, and accounting irregularities, these numbers routinely run into the billions. Even these numbers pale in comparison to lack of confidence from investors, the public, and a company s own management and employees. The cost of these ethics and compliance breakdowns is certainly not new and additional factors have elevated the consequences and likelihood of compliance risk: Ri s i n g r e g u lato ry c o m p lex ity c ou p le d with g r eate r r e g u lato ry e n f o rc e m e nt an d f i n i n g auth o r ity. For example, companies face large penalties related to the UK Bribery Act, the Dodd-Frank financial regulation, and an assortment of industry-specific regulations. pr e s s u r e f o r n ew r eve n u e i n s low g rowth e c o n o m i e s an d u n fam i liar mar k ets. Often these markets have substantially different commercial and cultural norms, creating very real risks as firms try to reconcile fast growth and rapid local hiring with heightened regulatory expectations. As a result of this increased scrutiny * Leslie Altizer is Director of the CEB Compliance and Ethics Leadership Council.
2 Median Compliance and Ethics Budget 2012 Median Compliance and Ethics Full-time Staff Average Number of Hours of Compliance and Ethics Training Required of ALL Employees Global Average $1,500, Pharmaceuticals and Biotechnology $3,500, Banking and Financial Services $5,000, Insurance $11,700, Figure 1: Key Compliance and Ethics Program Benchmarks of Highly Regulated Industries and attention from regulators, companies particularly in heavily regulated industries have heavily invested in bolstering the compliance infrastructure with steps such as large compliance budgets and teams, frequent policy updates, and additional training curriculum. (See figure 1 1 ). However, these steps only address a small part of the potential problem at best. While such foundational program elements represent critical building blocks, they often fail to actually change employee behavior. Often, organizational culture or the unwritten rules not process breakdowns, serve as the root cause of compliance failures. The most successful companies make the long-term investment to build a strong culture of integrity and these companies enjoy benefits such as reduced compliance violations, improved risk detection, higher employee productivity, and stronger financial performance. 1 Source: CEB 2012 State of the Compliance and Ethics Function Benchmarking Survey of 267 companies. Survey data was collected from CEB RiskClarity, a ethical cultural survey measuring employee perceptions of integrity at their companies. Data was collected from 24 global companies across Improving Your Culture of Integrity Reduces Misconduct and Increases Risk Detection If you polled 10,000 compliance and ethics officers and asked them what outcomes they care the most about for their programs, the majority of responses are likely to center on reduced number of compliance violations and increased ability to detect violations when they occur. These two critical outcomes are what most compliance and ethics activities are targeting and attempting to influence. And while investments in bolstering the ethics and compliance infrastructure and systems are important, culture is ultimately your greatest ally. To illustrate, despite significant dollars spent on hotlines and other reporting mechanisms, only about 5 percent of employee reports ever make it into the hotline. In fact, roughly half of observed misconduct never gets reported by employees and 60 percent of reported misconduct does not escalate beyond direct managers 2. However, companies 2 Source: 2012 CEB RiskClarity benchmark database of 293,326 global employees across 25 companies.
3 8 Responses on the CEB RiskClarity Integrity Index* Employees, on average, responded Somewhat Disagree, Disagree, or Strongly Disagree Employees, on average, responded Neither Agree nor Disagree Employees, on average, responded Somewhat Agree Employees, on average, responded Agree or Strongly Agree Unfavorable 5.9% Neutral 9.4% Favorable 20.9% Most Favorable 63.7% Observation Rate** Reporting Rate*** *The Integrity Index is an 18-question index score a company receives as part of the CEB RiskClarity survey. The questions are on a 7-point Strongly Agree to Strongly Disagree scale; **Percent of employees within category who observed misconduct in past year; ***Percent of employees within category who reported the misconduct they observed Figure 2: Impact of Cultures of Integrity on Key Compliance and Ethics Program Outcomes with strong cultures of integrity 3 face far fewer percentages of employees observing misconduct and a much larger percentage of employees reporting observations or concerns than those companies with weaker cultures of integrity (see figure 2 4 ). A Strong Culture of Integrity Can Net Greater Employee Productivity and Financial Gains In addition to the dollars saved through decreased compliance violations and proactive risk identification, companies can also drive increased employee performance and stronger financial gains through investments in integrity capital. CEB analyzed financial, operational, and cultural data from 34 publicly traded 3 A strong culture of integrity is measured and defined using the CEB RiskClarity Integrity Index. The Integrity Index is a series of questions measuring the strength of employee perceptions as related to key behaviors associated with high integrity (e.g., employee comfort speaking-up and tone-at-the-top). 4 Source: 2012 CEB RiskClarity benchmark database of 293,326 global employees across 25 companies. companies to better understand the linkages between culture and business performance. First, regression analysis showed that top quartile companies outperformed bottom quartile 5 companies in 10-year Total Shareholder Returns. As Figure 3 shows, those companies that have made culture a strategic priority have seen up to 16 percentage point higher total shareholder return than those companies that have been less successful in building cultures of integrity. (See figure 3 on the next page 6 ). Secondly, additional analysis found a strong connection between managers demonstrating corporate values and ethical behavior and overall employee performance, measured as discretionary 5 CEB divided the 34 companies into top and bottom quartile groups based upon their scores on the Integrity Index. Top quartile companies scored at or above the 75 th percentile and bottom quartile companies scores at or below the 25 th percentile. 6 Source: 2010 CEB Compliance and Ethics Leadership Council s Ethical Leadership Research
4 9 Average 10-Year Total Shareholder Return for Bottom and Top Quartile Companies Bottom Quartile of Integrity Index -7.4% 8.8% Top Quartile of Integrity Index Correlation (r) = 0.58 ; n=34 ; Significance level of Correlation: P-value < 0.01 Figure 3: Higher Integrity, Stronger Long-Term Total Shareholder Returns effort 7. In fact, when managers act as strong ambassadors for compliance and ethics conduct, employee discretionary effort increases by as much as 12 percent. As explained in the next section, ethical leaders at all levels of management play critical roles in driving culture throughout the organization. While it is likely that business performance and corporate culture both, to some degree, drive the other, it seems clear that cultures where employees freely speak-up to honest, respectful senior leaders increase financial gains, improve employee productivity, and better avoid risk management pitfalls. Defining a Culture of Integrity The benefits are clear so how do you put all the pieces together? Defining and understanding a culture of integrity is not always easy and building and fostering one can feel even more intimidating. Companies routinely face challenges and 7 Discretionary effort is the respondent s willingness to expend effort beyond typical expectations. Examples of this behavior include willingness to invest additional time and effort to accomplish a task or looking for ways to perform one s job more effectively. push back when implementing strategies to effectively drive desired employee behaviors. Compliance and ethics officers often find themselves asking questions such as: H ow d o I d e f i n e a c u lt u r e o f i n t e g r i t y w i t h i n m y ow n c o m pany? A culture of integrity addresses behaviors that drive employees to commit violations or not report concerns upwards, causes may differ from company to company. h ow ca n I c r e at e s t r o n g e r eth i cal lead e r s an d b uy-i n? Leaders at all levels of a company may not appreciate the importance of culture, be insufficiently accountable for compliance and ethics, and/or not understand how to be strong ethical leaders. How do I m easure culture an d th e n c r eate e f f e ctive acti o n p lan s? Measuring abstract behaviors and perceptions are not always easy to translate into tangible action steps that are linked to positive outcomes.
5 10 Through our employee-based culture survey, CEB RiskClarity, we surveyed more than 1,000,000 global employees to help companies define, measure, and build strong cultures of integrity. Companies with strong cultures of integrity as measured through CEB RiskClarity s Integrity Index all share common characteristics. 1 E t h i c a l L e a d e r s h i p a c r o s s all leve ls o f manag e m e nt. CEB defines Ethical Leadership as those managerial attributes which inspire employees to deliver high performance results against business objectives while embodying the values of the organization. Key characteristics of ethical leaders are honesty, accountability for actions of self and others, respect, trust, and listening. 2 Awar e n e s s o f h ow to r e p o rt c o n c e r n s o r vi o lati o n s. CEB has found that leading companies develop policies and procedures that formalize corporate efforts to encourage employees speaking up. These efforts include escalation policies, decisionmaking criteria, and training curriculum all of which is clearly articulated and available to employees. 3 Em ployees who are not fearful o f r etaliati o n i f th ey r e p o rt a c o n c e r n o r vi o lati o n. The primary reason employees fail to report observed misconduct is fear of retaliation. The best companies directly address employees fear of retaliation by creating cultures of risk awareness and comfort speaking up. 4 E m p l o y e e s w h o h av e f a i t h i n t h e r e p o r t i n g a n d di sci p li nary p roce ss du b b e d o rgan i zati o nal j u sti c e. When employees feel that their companies do not deal with reports of misconduct appropriately, perceptions of ethical culture decline dramatically. The best companies act decisively on instances of misconduct and publicly demonstrate corporate commitment to upholding compliance and ethics expectations. Let s take a moment and explore how companies have successfully used these building blocks to form, foster, and sustain their own cultures of integrity.
6 11 Focus on four vital leader qualities and rigorously measure management integrity. Leaders behavior shapes subordinates behavior. Although this may seem cliché or obvious, it is a true and vital fact supported by our analyses. A company that effectively implements dozens of processes and systems designed to enable information flow but does not have leaders with the right qualities will fail. Although 20 qualities often associated with strong leaders are laudable, only the following four are statistically proven to both foster a healthy culture and reduce the likelihood of misconduct: Organizational justice Honesty and integrity Respecting and trusting employees Listening carefully to the opinions of others All companies expect their managers to have integrity; however, companies with strong cultures of integrity go much further by rigorously measuring the integrity of their management teams. They use both objective and subjective measures and give each manager a score that ties to their promotion and variable compensation. As managers rise in the organization, they are expected to achieve increasingly high, clearly defined levels of integrity. Managers are provided and subject to training, communication, and enforcement mechanisms customized to their level. For example, companies may require their senior-most executives to repay bonuses granted for up to five of the preceding years if an appropriate action could have prevented a direct report s violation of an applicable law that resulted in financial loss. Leading companies objective measures include: Staff training and certification completion rates, Cultural survey scores (percentage rank relative to peers), Frequency of formal staff communications that reinforce corporate values, and
7 12 Completion of compliance goals as set forth in risk mitigation plans. Leading companies subjective measures include: 360-degree values assessment, Feedback from exit interviews and focus groups, and Business unit compliance selfassessment results. Establish company-wide speaking-up protocols and train your workforce. In order for employees to escalate concerns appropriately, companies must set a clear, easy-to-find speaking-up policy as part of the code of conduct or as a standalone policy. The policy will clearly identify what constitutes a violation or concern, provide at least one phone number for reporting, and should provide a means to report anonymously. Some companies will even build a webform that employees can use to actually submit a report. Sixty-nine percent of companies require their entire workforce to complete training on recognizing and reporting misconduct at least every three years 8. Leading companies will also develop creative and innovative roll-out strategies to raise awareness around how to report concerns. These companies will utilize posters, manager-led training, tear sheets, intranet sites, and/or newsletters to provide engaging communications to their workforce. Alleviate fear of retaliation by creating open and honest work environments. Regardless of policies and escalation criteria, employees are not likely to elevate risk information if they have a fear of retaliation. Of employees that observed misconduct in the past year but did not report it, nearly one-third of those employees chose not report because they feared retaliation 9. 8 Source: CEB 2012 State of the Compliance and Ethics Function Benchmarking Survey of 267 companies. 9 Source: 2012 CEB RiskClarity benchmark database of 293,326 global employees across 25 companies.
8 13 Retaliation can take many forms in the workplace including being ostracized by peers, loss of compensation or job, passed over for opportunities, just to name a few. Often, employees will form perceptions that retaliation exists without ever truly experiencing retaliation or by perceiving certain behaviors to be retaliation even if that is not the intention of the other employee(s). To help mitigate the risk of retaliation, real or otherwise, companies should: Develop a clear non-retaliation policy and train all levels of employee; Take disciplinary action against employees who have committed retaliation against reporters; Measure employee perceptions of retaliation in the workplace through employee surveys or focus groups; Train managers to respond appropriately and consistently to employee reports of misconduct; and Provide managers (and ethics liaisons) the tools and resources to handle concerns to prevent perceptions of retaliation. Deliver organizational justice by responding quickly and consistently to unethical practices. A company s culture has organizational justice when employees agree that 1) their company responds quickly and consistently to verified or proven unethical behavior and 2) unethical behavior is not tolerated in their department. Organizational justice as a driver of culture is almost three times more powerful than all other leading drivers combined. To advocate organizational justice, leading companies focus not only on convincing employees, but also on quickly identifying misconduct. In addition, they mitigate future misconduct and reduce potential offenders over time by attracting and retaining the right employees. While most companies effectively respond to illegal or unethical behavior, most employees (even most managers) never know it. Leading companies show employees that when unethical behavior is uncovered, people are held
9 14 accountable, and the company does the right thing. To foster organizational justice, leaders should: Set clear expectations that unethical behavior is not tolerated; Hold employees at all levels consistently accountable; and Share details regarding detected, punished misconduct (within the bounds of privacy laws). Find your hidden, weak links and target efforts on the least compliant areas. Ultimately, what gets measured gets done. Measurement should be at the beginning, middle, and end of every cultural strategy implemented. Measurement uncovers areas of risk, potentials challenges, and bright spots that would otherwise remain hidden. Even for companies that enjoy strong cultures of integrity, this critical risk remains: the lowest scoring business unit, region, or department is often ignored when executives only see averaged results. The likelihood of an employee speaking up about a compliance issue often varies by 30 percentage points or more between the most and least compliant groups. Leading companies focus attention on the least compliant locations, especially by gathering information directly from employees who work there. Face-to-face interaction with frontline employees provides them a more detailed and accurate picture of local manager and peer behavior than broad surveys can provide. After developing a clear understanding of local challenges, leading companies managers develop and implement remediation plans that include intense coaching and training. Summary Global organizations are facing ever more costly compliance and ethical failures. In response, such organizations have developed and are spending a lot of money on compliance programs, risk management and training for their employees. While such measures can help, Compliance & Ethics Officers experience marginal returns on investment at best, without creating a sustainable, longterm change that actually reduces
10 15 misconduct or increases the chance of earlier identification. By contrast, those organizations that consistently focus on defining, measuring and fostering a culture of integrity stand a much higher chance of long-term success. At a minimum, Compliance & Ethics Officers together with other functional partners like HR should create an open environment of communication, where employees feel comfortable speaking up about the good, the bad and the ugly news they hear. Essential to comfort speaking up is establishing zero toleration for retaliation, as well as assuring employees that when employees report misconduct, swift and just action of the company will follow and employees at every level of the organization will be held accountable. M Leslie Altizer is the Director of the CEB Compliance and Ethics Leadership Council which provides research and advisory support for compliance and ethics officers worldwide. Leslie also manages the CEB RiskClarity Service which is an employee perception tool measuring key cultural risks within a company. Leslie has nearly 10 years of experience supporting ethics and compliance teams with core program activities such as general program management, measurement & assessment, identifying & mitigating corporate risk, and training & communication strategies. Leslie has also spent a considerable portion of his career consulting with directors of Human Resources and ethics and compliance officers on effectively measuring employee perceptions of corporate culture and engagement. Prior to joining CEB in 2010, Leslie spent 4+ years with the Ethics Resource Center (ERC) managing their research and client-related survey tools such as the 2009 National Business Ethics Survey and the Defense Industry Initiative Benchmarking Survey. Leslie has presented research at numerous compliance and ethics events such as the Ethics and Compliance Officer Association, Practicing Law Institute, and the Society for Corporate Compliance and Ethics. He has a Bachelor of Arts degree in Psychology and a Master of Sciences degree in Industrial/Organizational Psychology.
The Compliance and Ethics Essentials Toolkit
CEB Compliance and Ethics Leadership Council The Compliance and Ethics Essentials Toolkit Practical Resources to Accelerate the Development of Your Program Contact CEB to Learn More +1-866-913-8103 CELC_Support
More informationIntegrity Continuity: Avoiding and Surviving (Un)Ethical Disasters. Robert C. Chandler, Ph.D., Pepperdine University Malibu, California USA
Integrity Continuity: Avoiding and Surviving (Un)Ethical Disasters Robert C. Chandler, Ph.D., Pepperdine University Malibu, California USA Changing our Minds It couldn t happen to us a false sense of security,
More informationUnderstanding Your Ethics & Code of Conduct Training Requirements. May 29, 2008
Understanding Your Ethics & Code of Conduct Training Requirements May 29, 2008 Shanti Atkins, Esq. President & CEO of ELT. Specialist in online ethics and legal compliance training. Advises clients across
More informationTHE HR GUIDE TO IDENTIFYING HIGH-POTENTIALS
THE HR GUIDE TO IDENTIFYING HIGH-POTENTIALS What makes a high-potential? Quite possibly not what you think. The HR Guide to Identifying High-Potentials 1 Chapter 1 - Introduction If you agree people are
More informationCode of Business Conduct and Ethics. With Special Message for Senior Business and Finance Leaders
Code of Business Conduct and Ethics With Special Message for Senior Business and Finance Leaders Index Letter from our Chairman & CEO and from our President Annual Letter to Senior Leaders Introduction
More informationCreating and Maintaining an Effective Ethics and Business Conduct Program
Creating Maintaining an About DII The Defense Industry Initiative on Business Ethics Conduct (DII) is an organization comprised of companies that provide systems, professional services, weapons, technology,
More informationCompliance Requirements for Healthcare Carriers
INFORMATION DRIVES SOUND ANALYSIS, INSIGHT REGULATORY COMPLIANCE ADVISORY Compliance Requirements for Healthcare Carriers Introduction With the introduction of the new healthcare exchanges in January 2014
More informationEmployee Engagement Survey Results. Sample Company. All Respondents
Employee Engagement Survey Results All Respondents Summary Results from 246 Respondents February, 2009 Table of Contents All Respondents (n = 246) 1 Employee Engagement Two-Factor Profile of Employee Engagement
More informationKey Trends, Issues and Best Practices in Compliance 2014
Key Trends, Issues and Best Practices in Compliance 2014 What Makes This Survey Different Research conducted by independent third party Clients and non-clients 301 executive decision makers 35 qualitative
More informationRetaliation: The Cost to Your Company and Its Employees
Retaliation: The Cost to Your Company and Its Employees This report is published by the Ethics Resource Center (ERC). All content contained in this report is for informational purposes only. The Ethics
More informationHow To Fix A Broken Performance Management Program How Leading Organizations are transforming Performance Management to maximize Business Value
Orange County Convention Center Orlando, Florida June 3-5, 2014 How To Fix A Broken Performance Management Program How Leading Organizations are transforming Performance Management to maximize Business
More informationCorporate Compliance and Ethics Program Effective as adopted on February 21, 2012
Corporate Compliance and Ethics Program Effective as adopted on February 21, 2012 Page 1 of 7 SECTION 1. STATEMENT OF INTENT As a specialty pharmaceutical company and diagnostic laboratory, Prometheus
More informationLeadership Pulse. www.leadershippulse.com www.eepulse.com info@eepulse.com
Leadership Pulse Pay for Performance Research Report on big picture results produced by Sibson, which was our partner for this particular Leadership Pulse study. On the next pages you will find a report
More informationThe SEC Whistleblower Program and What You Need to Know
Whitepaper: Regulatory The SEC Whistleblower Program and What You Need to Know Edited By: Ed Petry The Ethical Leadership Group On May 25th 2011, the U.S. Securities and Exchange Commission (SEC) took
More informationGUIDE TO EFFECTIVE STAFF PERFORMANCE EVALUATIONS
GUIDE TO EFFECTIVE STAFF PERFORMANCE EVALUATIONS The research is clear. The outcome is consistent. We know with certainty that the most powerful leadership tool for improving productivity and increasing
More informationPERFORMANCE MANAGEMENT SYSTEM
WHITE PAPER BY PATRICIA DAVIS LEADER, PERFORMANCE MANAGEMENT ROBERT W. ROGERS PRESIDENT, DDI WHITE PAPER GETTING THE MOST FROM YOUR 1 GETTING THE MOST FROM YOUR PERFORMANCE MANAGEMENT SYSTEM Is your organization
More informationCopyright 2012, General Dynamics Information Technology. All Rights Reserved.
Introduction Over the years, General Dynamics Information Technology has experienced significant growth in its IT services business serving government and commercial customers worldwide. As a valued supplier
More informationSTAYING AHEAD OF THE PACK: EMERGING TRENDS & ISSUES WHISTLEBLOWING AFTER DODD-FRANK: A NEW WORLD
STAYING AHEAD OF THE PACK: EMERGING TRENDS & ISSUES WHISTLEBLOWING AFTER DODD-FRANK: A NEW WORLD The Dodd-Frank Wall Street Reform and Consumer Protection Act created incentives for whistleblowers to report
More informationCompliance in motion A closer look at the Corporate Sector. Deloitte Risk Services March 2015
Compliance in motion A closer look at the Corporate Sector Deloitte Risk Services March 2015 2 Contents Preface 5 Management summary 6 The compliance culture 7 Compliance priorities for the next five years
More informationMasters Comprehensive Exam and Rubric (Rev. July 17, 2014)
1 Educational Leadership & Policy Studies Masters Comprehensive Exam and Rubric (Rev. July 17, 2014) The comprehensive exam is intended as a final assessment of a student s ability to integrate important
More informationHigher Performing High Schools
COLLEGE READINESS A First Look at Higher Performing High Schools School Qualities that Educators Believe Contribute Most to College and Career Readiness 2012 by ACT, Inc. All rights reserved. A First Look
More information15 December 2015. Crime Prevention and Anti-Fraud Policy
15 December 2015 Crime Prevention and Anti-Fraud Policy Content 1. Purpose 3 2. Scope 3 3. Action Principles 3 4. Control, Evaluation, and Revision 4 Look after the Environment. Print in black and white,
More informationThe IIA Global Internal Audit Competency Framework
About The IIA Global Internal Audit Competency Framework The IIA Global Internal Audit Competency Framework (the Framework) is a tool that defines the competencies needed to meet the requirements of the
More informationWhat Do The Numbers Tell Us?
2010 COURT EMPLOYEE SATISFACTION SURVEY ADMINISTRATIVE OFFICE OF THE NINETEENTH JUDICIAL CIRCUIT COURT OF LAKE COUNTY, ILLINOIS What Do The Numbers Tell Us? Nineteenth Judicial Circuit Court of Lake County,
More information1-2 Corporate Compliance Practice Guide 2.03. Corporate Compliance Practice Guide
1-2 Corporate Compliance Practice Guide 2.03 Corporate Compliance Practice Guide Copyright 2009, Matthew Bender & Company, Inc., a member of the LexisNexis Group. Chapter 2 Creating a Basic Compliance
More informationUSDA New Supervisor Training Standard
USDA Virtual University, College of Leadership and Professional Development United States Department of Agriculture Office of Human Resources Management Virtual University 1400 independence Avenue, SW
More informationOur Shared Responsibility to Our Clients, Colleagues and Communities
Our Shared Responsibility to Our Clients, Colleagues and Communities Code of Business Conduct and Ethics To the People of Goldman Sachs: Since our beginnings as a family business in 1869, Goldman Sachs
More informationOur Lady of the Lake University
Our Lady of the Lake University Executive Summary 2010 ID: 875 Executive Summary Table of Contents Introduction 1 Survey Framework & Administration 1 Organization Profile 2 Synthesis Score & Response Rates
More informationCore Leadership Competencies
Core Leadership Competencies The following guidance further clarifies the distinctions between levels of performance for the 8 core competencies outlined in Element 1 of all DHS SES performance plans.
More informationBUSINESS ETHICS: Training Beyond Compliance and HR. Business Ethics White Paper January 2013
Business Ethics White Paper January 2013 BUSINESS ETHICS: Training Beyond Compliance and HR Chuck Gallagher, founder of the Ethics Resource Group, is an international business ethics consultant and trainer
More informationLeadership Development Catalogue
The TrainingFolks Approach The importance of superior management, leadership and interpersonal skills are critical to both individual and organizational success. It is also critical to apply these skills
More informationProfessional and ethical standards
Victoria Police Manual Policy Rules Professional and ethical standards Context Purpose The Victoria Police mission is to provide a safe, secure and orderly society by serving the community and the law.
More informationEmployee Engagement Special Report
Employee Engagement Special Report Leveraging Engagement for Profitability What is an engaged employee and how important are they to my business? An engaged employee cares about more than just receiving
More informationAntifraud program and controls assessment grid*
Advisory Services Antifraud program and * Fraud risks & controls February 2008 *connectedthinking 2008 PricewaterhouseCoopers LLP. All rights reserved. PricewaterhouseCoopers refers to PricewaterhouseCoopers
More informationBusiness Administration Certificate Program
Business and Management Business Administration Certificate Program extension.uci.edu/busadmin University of California, Irvine Extension s professional certificate and specialized studies Improve Your
More informationThe University of Texas at Austin
REPORT ID: 721 Introduction & Survey Framework... 1 Organization Profile & Survey Administration... 2 Overall Score & Participation... 3 Construct Analysis... 4 Areas of Strength... 5 Areas of Concern...
More informationfor Sample Company November 2012
for Sample Company November 2012 Sample Company 1800 222 902 The Employee Passion Survey Passionate employees are focused, engaged and committed to doing their best in everything they do. As a result,
More informationI. Introduction. 1919 Madison Avenue, New York, NY 10035 tel: 212-987-1777 toll free: 866-778-6827 fax: 212-987-1776
I. Introduction The Ralph Lauren Center for Cancer Care ( RLCCC or The Center ) operates a freestanding diagnostic and treatment center, licensed under Article 28 of the New York State health law, located
More informationAPEC General Elements of Effective Voluntary Corporate Compliance Programs
2014/CSOM/041 Agenda Item: 3 APEC General Elements of Effective Voluntary Corporate Compliance Programs Purpose: Consideration Submitted by: United States Concluding Senior Officials Meeting Beijing, China
More informationStandards of. Conduct. Important Phone Number for Reporting Violations
Standards of Conduct It is the policy of Security Health Plan that all its business be conducted honestly, ethically, and with integrity. Security Health Plan s relationships with members, hospitals, clinics,
More informationPrepared for: Your Company Month/Year
Prepared for: Your Company Month/Year This sample is a condensed version showing selections from an actual 4Cs Comprehensive Employee Survey Analysis report and balloons explaining the main features of
More informationAligning Compliance Program Priorities with Business Objectives
Aligning Compliance Program Priorities with Business Objectives By Jay G. Martin Vice President, Chief Compliance Officer and Senior Deputy General Counsel Baker Hughes Incorporated CAIL Institute for
More informationCode of Ethics and Professional Conduct
Code of Ethics and Professional Conduct CHAPTER 1. VISION AND APPLICABILITY 1.1 Vision and Purpose As practitioners of project management, we are committed to doing what is right and honorable. We set
More informationProfessional. Compliance & Ethics. A global compliance career. an interview with Sally March. See page 14
Compliance & Ethics July/August 2013 Professional a publication of the society of corporate compliance and ethics www.corporatecompliance.org A global compliance career an interview with Sally March Director,
More informationFifth annual survey. Look before you leap Navigating risks in emerging markets
Fifth annual survey Look before you leap Navigating risks in emerging markets Table of contents 1 Executive summary 3 Significant concerns over compliance and integrity-related risks 4 Bribery leads the
More informationWOLTERS KLUWER COMPANY VALUES AND BUSINESS PRINCIPLES
WOLTERS KLUWER COMPANY VALUES AND BUSINESS PRINCIPLES Mission statement and introduction Wolters Kluwer s customers face critical decisions every day; and the need to get them right. That is why Wolters
More informationCorporate Compliance and Ethics
Corporate Compliance and Ethics Title: Corporate Compliance and Ethics Course Code: EL-CCE-COMP-0 Course Outline Section 1: Introduction A. Course Contributors B. About This Course C. Learning Objectives
More information2012 Allied Workforce Mobility Survey: Onboarding and Retention
About the 2012 Research The 2012 Allied Workforce Mobility Survey, conducted in March 2012, captures the voice of HR professionals on critical topics relating to workforce mobility, which is defined as
More informationECOVADIS CODE OF ETHICS
ECOVADIS CODE OF ETHICS January 2015 TABLE OF CONTENTS WHY A CODE OF ETHICS?...1 OUR VISION 1 SCOPE OF APPLICATION.1 ECOVADIS ORGANIZATION..2 PART 1: PRINCIPLES OF ECOVADIS CSR RATINGS.3 QUALITY OF CSR
More information360-Degree Assessment: An Overview
360-Degree Assessment: An Overview United States Office of Personnel Management Performance Management and Incentive Awards Division This material was developed with the assistance of Human Technology,
More informationJULY 1, 2010 JUNE 30, 2013 STRATEGIC PLAN
DEPARTMENT OF HUMAN RESOURCES JULY 1, 2010 JUNE 30, 2013 STRATEGIC PLAN Introduction Human resource strategies are institutional efforts to support people (leaders, faculty and staff) to contribute to
More informationFrom Capability To Profitability Talent management a priority for the C-Suite. London, 3 rd November 2015
From Capability To Profitability Talent management a priority for the C-Suite London, 3 rd November 2015 Contents 1 The challenge of talent management 2 Select Top-of-the-Agenda talent trends 3 Example:
More informationCapitalizing on Effective Communication
Capitalizing on Effective Communication How Courage, Innovation and Discipline Drive Business Results in Challenging Times 2009/2010 Communication ROI Study Report Originally published by Watson Wyatt
More informationU.S. CORPORATE ETHICS AND COMPLIANCE POLICY
U.S. CORPORATE ETHICS AND COMPLIANCE POLICY Table of Contents Page 1. Letter from the President & CEO 3 2. Introduction 4 3. How to Handle and Report Ethical and/or Compliance Issues 5 3.1 Violations of
More informationSTRATEGIES FOR KEEPING A WHISTLEBLOWER IN-HOUSE. By Susan Goetz Markel
STRATEGIES FOR KEEPING A WHISTLEBLOWER IN-HOUSE By Susan Goetz Markel In 2012, the Securities and Exchange Commission issued its first whistleblower award under the new program ushered in by the Dodd-Frank
More informationSTATE OF THE RETAIL INDUSTRY: EXECUTIVE SUMMARY
STATE OF THE RETAIL INDUSTRY: EXECUTIVE SUMMARY State of the Retail Industry The retail industry is beginning to show modest signs of recovery. However, consumers remain cautious. Consumer confidence is
More informationGuide to Effective Staff Performance Evaluations
Guide to Effective Staff Performance Evaluations Compiled by Human Resources Siemens Hall, Room 211 The research is clear. The outcome is consistent. We know with certainty that the most powerful leadership
More informationPrepared by: The Office of Corporate Compliance & HIPAA Administration
Gwinnett Health System s Annual Education 2014 Corporate Compliance: Our Commitment to Excellence Prepared by: The Office of Corporate Compliance & HIPAA Administration Objectives After completing this
More informationHuman Resources Best Practices Audit and Needs Assessment Tool
Human Resources Best Practices Audit and Needs Assessment Tool The Employers Choice Inc. 2 County Court Blvd., Suite 430 Brampton, ON L6W 3W8 Tel: 905-874-1035 Fax: 905-874-0280 Web: www.theemployerschoice.com
More information50 EMPLOYEE ENGAGEMENT. IDEAS and TIPS A LEADER S GUIDE TO EMPLOYEE ENGAGEMENT
50 EMPLOYEE ENGAGEMENT IDEAS and TIPS A LEADER S GUIDE TO EMPLOYEE ENGAGEMENT ! 50 EMPLOYEE ENGAGEMENT IDEAS and TIPS: 50 EMPLOYEE ENGAGEMENT IDEAS AND TIPS 1 2 3 4 5 BE A BETTER BOSS! Immediate manager
More information:-) Doing the right thing Starts with reading the right thing. Philips General Business Principles, your guide to acting with integrity
General Business Principles Doing the right thing Starts with reading the right thing :-) Philips General Business Principles, your guide to acting with integrity pww.gbp.philips.com June 2014 We re on
More informationEXECUTIVE SAFETY LEADERSHIP
EXECUTIVE SAFETY LEADERSHIP EXECUTIVE SUMMARY This guide offers clear explanations of health and safety concepts that are important to executives and board members, and provides practical solutions that
More information2016 The global ABB integrity program. www.abb.com/integrity
2016 The global ABB integrity program www.abb.com/integrity Tone from the Top Don t Look the Other Way A culture of integrity is a prerequisite for a world-class business. Many valuable customers choose
More informationEthics Everywhere Jones Lang LaSalle Incorporated Annual Report for Calendar Year 2013 Program
Ethics Everywhere Jones Lang LaSalle Incorporated Annual Report for Calendar Year 2013 Program Introduction JLL is committed to a corporate culture that embraces and promotes strong principles of business
More informationHCA ETHICS AND COMPLIANCE PROGRAM
HCA ETHICS AND COMPLIANCE PROGRAM The HCA Ethics and Compliance Program is intended to accomplish two goals. One of these goals is trying to ensure that everyone associated with HCA-affiliated facilities
More informationAnne Novick Branan, Esq. Broad and Cassel Fort Lauderdale, FL abranan@broadandcassel.com
Anne Novick Branan, Esq. Broad and Cassel Fort Lauderdale, FL abranan@broadandcassel.com 1 The False Claims Act protects employeewhistleblowers from retaliation by their employer. Companies should reports
More informationCrime Prevention and Anti- Fraud Policy of Gamesa Corporación Tecnológica, S.A. (March 23, 2011)
Crime Prevention and Anti- Fraud Policy of Gamesa Corporación Tecnológica, S.A. (March 23, 2011) I. PURPOSE The Board of Directors of Gamesa Corporación Tecnológica, S.A. (the Company or Gamesa) has been
More informationINSTITUTIONAL COMPLIANCE PLAN
INSTITUTIONAL COMPLIANCE PLAN Responsible Party: Board of Trustees Contact: Institutional Compliance Office Original Effective Date: 02/16/2012 Last Revised Date: 10/13/2014 Contents I. SCOPE OF THE PLAN...
More informationDeloitte Forensic Fraud Risk Management
Deloitte Forensic Fraud Risk Management Introduction Organizations cannot afford to be unconcerned about the risk of fraud. Directors and management have a fiduciary obligation and a corporate responsibility
More informationOffice of Human Resources. Financial Manager
Office of Human Resources Financial Manager Page 1 of 6 GENERAL STATEMENT OF CLASS DUTIES Manages financial functional and/or operational area(s) that include implementing work plans based on annual goals
More informationWorkforce Insights Employee Satisfaction Surveying
Workforce Insights Employee Satisfaction Surveying Overview One significant factor in your call center s success is how happy and satisfied the employees are. Employee satisfaction has an extremely high
More informationBusiness Analyst Position Description
Analyst Position Description September 4, 2015 Analysis Position Description September 4, 2015 Page i Table of Contents General Characteristics... 1 Career Path... 2 Explanation of Proficiency Level Definitions...
More informationIT TALENT MANAGEMENT FOR MID-MARKET COMPANIES
IT TALENT MANAGEMENT FOR MID-MARKET COMPANIES FOR IT DEPARTMENTS, CONNECTING WITH TOP TALENT IS CRITICAL In the rapidly evolving world of business, hiring and maintaining a competent IT department is essential
More informationA MESSAGE FROM THE ACTING DIRECTOR OF THE OFFICE OF PERSONNEL MANAGEMENT
Disciplinary Best practices and advisory GuiDelines under the no Fear act September 2008 A MESSAGE FROM THE ACTING DIRECTOR OF THE OFFICE OF PERSONNEL MANAGEMENT I am pleased to release the report Disciplinary
More informationHuman factors is the term used to describe the interaction
Human factors defined Human factors is the term used to describe the interaction of individuals with each other, with facilities and equipment, and with management systems. This interaction is influenced
More informationUNIVERSITY OF CALIFORNIA CODE OF CONDUCT FOR TRADEMARK LICENSEES (Revised January 5, 2000)
UNIVERSITY OF CALIFORNIA CODE OF CONDUCT FOR TRADEMARK LICENSEES (Revised January 5, 2000) It is the policy of the University of California that trademark licensees for goods produced with UC logos agree
More informationThree things managers must do to make the most of cognitive computing by Ryan Shanks, Sunit Sinha and Robert J. Thomas
Managers and machines, unite! Three things managers must do to make the most of cognitive computing by Ryan Shanks, Sunit Sinha and Robert J. Thomas Intelligent machines are poised to dramatically shift
More information2010 BEST PRACTICES FORUM. October 11 12, 2010 The Four Seasons Resort & Club at Dallas
2010 BEST PRACTICES FORUM October 11 12, 2010 The Four Seasons Resort & Club at Dallas 1 Techniques for Auditing/Monitoring/Reviewing Your Ethics and Compliance Program A discussion led by our seasoned
More informationPOLICY SUBJECT: EFFECTIVE DATE: 5/31/2013. To be reviewed at least annually by the Ethics & Compliance Committee COMPLIANCE PLAN OVERVIEW
Compliance Policy Number 1 POLICY SUBJECT: EFFECTIVE DATE: 5/31/2013 Compliance Plan To be reviewed at least annually by the Ethics & Compliance Committee COMPLIANCE PLAN OVERVIEW Sound Inpatient Physicians,
More informationKey Elements for Effective Compliance Program Board Reporting
WHITEPAPER Key Elements for Effective Compliance Program Board Reporting By Randy Stephens, JD, CCEP, VP of NAVEX Global s Advisory Services Team Know your audience. It s a cardinal rule of business communications
More informationINTRODUCTION. to the Nurse Manager Inventory Tool. Methodology for How to Use the Nurse Manager Inventory Tool
INTRODUCTION to the Nurse Manager Inventory Tool The critical influence of nurse managers in shaping healthy work environments is undeniable. Of every leadership role in health care today, a nurse manager
More informationThe way we do business.
a b The way we do business. Our Code of Conduct and Ethics. Our Code of Conduct and Ethics In this Code, the Board of Directors and the Group Executive Board set out the principles and practices that define
More informationWhitepaper. Beyond Compliance: Implementing Effective Whistleblower Hotline Reporting Systems
Whitepaper Beyond Compliance: Implementing Effective Whistleblower Hotline Reporting Systems Introduction Hotline reporting systems have been in use for more than two decades, and have proven an effective
More informationWhy Ethics Hotlines Are Considered a Best Practice
WhitePaper Why Ethics Hotlines Are Considered a Best Practice 3/18/16 Table of Contents Abstract.. 2 The Call for Higher Ethical Standards.....4 Specific Ethical Concerns...5 Best Practices and Reporting
More informationApproved by the Audit and Compliance Committee of the Providence Health & Services Board of Directors
Integrity and Compliance Description Approved by the Audit Committee of the Providence Health & Services Board of Directors December 7, 2009 Contents: Introduction Page 1 Purpose Page 2 Compliance Administration
More informationThe 360 Degree Feedback Advantage
viapeople Insight - Whitepaper The 360 Degree Feedback Advantage How this powerful process can change your organization Karen N. Caruso, Ph.D. Amanda Seidler, Ph.D. The 360 Degree Feedback Advantage Champions
More informationUMDNJ COMPLIANCE PLAN
UMDNJ COMPLIANCE PLAN INTRODUCTION...2 COMPLIANCE OVERSIGHT 3 COMPLIANCE COMMITTEE STRUCTURE...4 CHIEF COMPLIANCE OFFICER S RESPONSIBILITIES...5 RESEARCH COMPLIANCE.5 UNIT IMPLEMENTATION.6 COMPLIANCE POLICIES
More informationHIGHLIGHTS REPORT. Department of Science Information Technology Innovation & the Arts
HIGHLIGHTS REPORT Department of Science Information Technology Innovation & the Arts Introduction The Highlight Report presents key results from the, which was conducted in May 2014. Results reflect the
More informationAdministrative Policy and Procedure Manual. Code of Conduct Effective Date: 1/2005 Scope: Organizationwide Page 1 of 9
Scope: Organizationwide Page 1 of 9 I. Purpose The purpose of this policy is to provide direction to staff members to assist in carrying out daily activities within appropriate ethical and legal standards.
More informationChapter 1: Health & Safety Management Systems (SMS) Leadership and Organisational Safety Culture
Chapter 1: Health & Safety Management Systems (SMS) Leadership and Organisational Safety Culture 3 29 Safety Matters! A Guide to Health & Safety at Work Chapter outline Leadership and Organisational Safety
More informationAT&T s Code of Business Conduct
August 2015 AT&T s Code of Business Conduct To All AT&T Employees Worldwide: The most basic commitment we make to our customers, our shareholders, and each other is to always conduct ourselves in an ethical
More informationOrganizational culture
Note: We recognize that this discussion of organizational culture is based on a non-profit paid staff model of organization. We believe there are many ways to effectively and dynamically organize and that
More informationa. employees Company; or
Code of Busines ss Conduct and Ethics 1. Introduction a. This Code of Business Conduct and Ethics (the Code ) applies to all directors, officers, employees and third parties employed or directly engaged
More informationPHI Air Medical, L.L.C. Compliance Plan
Page No. 1 of 13 Introduction: The PHI Air Medical, L.L.C. is to be used by employees, contractors and vendors to get a high level understanding of the key regulatory requirements relating to our participation
More informationWHISTLE BLOWER POLICY
RAMCO SYSTEMS LIMITED WHISTLE BLOWER POLICY WHISTLE BLOWER POLICY 1. Objective The objective of this Whistle Blower Policy is to provide Directors and Employees (hereinafter collectively referred to as
More informationwww.pwc.com/workforce-analytics City and County of Denver 2015 Employee Engagement Survey
www.pwc.com/workforce-analytics City and County of Denver 2015 Employee Engagement Survey Prepared for and Presented to the City and County of Denver August 28, 2015 Overview Background Survey Objectives
More informationAstraZeneca US Compliance Program
AstraZeneca US Compliance Program Key Objectives AstraZeneca's US Compliance Program is focused on two equally important objectives: Exercising due diligence to prevent, detect and correct unlawful conduct
More informationSection Three: Ohio Standards for Principals
Section Three: Ohio Standards for Principals 1 Principals help create a shared vision and clear goals for their schools and ensure continuous progress toward achieving the goals. Principals lead the process
More informationPolicy-Standard heading. Fraud and Corruption Policy
Policy-Standard heading Fraud and Corruption Policy September 2013 Table of contents Introduction 3 Purpose 3 Scope 3 Related Policies and Processes 3 Definition of Fraud and Corruption 4 Policy 4 Code
More information