Everyone it seems has been the victim, at one time or another, of a deadly boring Code of Conduct or business ethics training session. The unintended consequence of such training is that it leaves employee’s jaded with management’s intent, angry at the waste of their time and frustrated by the lack of relevance of content when there were significant ethical challenges that might have been addressed. Such training also blindsides risk managers, boards and regulators into a false sense of security that employees are being forewarned and forearmed about the specific industry challenges they will inevitably face. After all, we do not know exactly where the high-risk areas are in each industry so is it any wonder that employees are not being given ample warning and specific skills training to anticipate and eliminate these risks?
So, why do so many business ethics and code of conduct training programs fail to engage employees and protect employers? As is the case with the design of organisational culture, much training fails simply because of its poor design and lack of resourcing.
The systemic source of poor design begins with an approach that takes a strictly legal or compliance perspective. Often the focus is on telling employees about what they can and can’t do Instead of recognising employees’ innate need to “make sense” of the codes they are being asked to sign up to, how they are to be applied to day to day activities and how they influence interpersonal relationships. This approach assumes everyone will make the same interpretation of workplace challenges so there is only a need for one right answer, and it will cover a myriad of situations arising in the service context, the marketing context or the sales context. It further assumes that employees, will interpret the code’s directives in the same way regardless of age, gender, race or educational background.
The traditional tired approach to Code of Conduct training stays silent on the informal cultural priorities that shape workplace behaviour choices. Cultural priorities such as obeying your boss; doing more with less because of budget cuts; making financial targets because personal and group bonuses depend on it; or getting reports in to meet deadlines with pressure to do whatever it takes to meet that deadline.
It stays silent on “the other message system” that prevails, the one where people ‘listen with their eyes’, see what behaviour is being rewarded and recognised and feel they have to either fall into line, vote with their feet and leave, or stay and sabotage as payback because the organisation does not walk its talk.
The recent trend to design content that includes ethical dilemmas or hypotheticals, that fosters and encourages a culture of discussion and conversation around real life examples about the real dilemmas that people face such as reporting managerial bullying, or obvious breaches of the Code by supervisors and managers. Instead, these hypotheticals are often designed to provide the organisation with legal coverage should a scandal emerge ; they speak to the black and white, the known, and not the contextual pressures that push people over the line – such as “stretch goals” that, for example, can mean stretching the espoused value of “customer care” to meet sales targets.
Lack of resourcing can mean that instead of face to face training, where the nuances of organisational culture, situation context and individual meaning making can be mediated, the obligatory annual online learning program is complete with a mandatory sign off so that the organisation can attest to the fact that all employees have been put through the ethical “sheep deep.” Such training may provide a compliance shield but regulators are becoming increasingly cynical about leaders’ failure to allocate sufficient resources to ensure their people know what is expected of them in pursuit of business goals and where the tolerances are. Progressive organisations make explicit the ‘how’ of business development and also that ‘must nots’ of living their values. The fact that so many high profile global brands such as Wells Fargo or Volkswagen or, here in Australia CommInsure, or Leighton Holdings, failed to ensure ethical standards of behaviour and suffered serious brand damage as well as loss of regulator and consumer confidence, doesn’t seem to have reset the default approach to code of conduct/ethics training.
So how do you design ethics or Code of Conduct training with integrity?
- Authenticity of content is the first principle. Instead of hypothetical dilemmas risk managers can canvass employees input, from the different levels within their organisations, to identify what, ethical challenges they face. This input can be canvassed anonymously to offset organisational power politics. Tailoring training content in this way ensures genuine situational and cultural challenges are being addressed. It wins over employee engagement and sends a powerful signal to regulators that leaders are genuine in their desire to create an ethical culture where employees are supported to do the right thing.
- The design of content also needs to be informed by the new behaviour sciences that highlight how organisational context trumps employee’s personal values causing them to behave in ways not of their choosing. Drawing on this field research employees are forewarned of “the slippery slopes” leading them towards unethical behaviour. Providing employees with information on how pressures to go along to get along can give rise to rationalisations justifying poor behaviour also forewarns employees on early signs of ethical fading. Behaviour science has delivered to organisational leaders a new range of very powerful levers to design the cultures they want. By sharing the field research with employees, they too can be engaged in the co-design of desired culture at every level.
- Training can also be timed to specific cultural contexts that are known as high risk contexts rather than focusing on high risk individuals. Employees can be skilled in how to offset specific organisational cultural pressures such as making end of month sales quotas; in the procurement areas how to offset the pressures from “relationship marketing” suppliers; when heavy organisational reengineering is happening, employees can be skilled to cope with change so they can continue to experience their organisations as fair places to work. Organisational justice research reminds us that if employees see the organisation as unfair, they are likely to retaliate with workplace sabotage, including fraud, data leaks and other misbehaviours.
- The frequency of codes’ training also matters. Ethical issues arise daily and conversations and timely and regular training that checks in with how employees are doing, signals that leaders are keen to make it as easy as possible for employees to do the right thing. A once a year eLearning program, that doesn’t speak to their concerns, sends a different signal about what’s important. The frequency of ethical conversations offsets “cultural drift” where informal ways of doing things gradually overtake the formal way of doing things as experienced widely in the banking scandals both at Australian and UK banks.
If leaders are serious about managing risk and designing cultures of choice, it’s time to reset the default button on code of conduct and business ethics training. Both employees and employers will reap the benefit of genuine workplace learning opportunities about the how and why of ethical business practices and accountabilities.