In a five-part podcast series I am running this week on the Compliance Podcast Network, I visit with Vincent DiCianni, founder and Chief Executive Officer (CEO), and Eric Feldman, Senior Vice President both of Affiliated Monitors, Inc. (AMI), the sponsor of this series. In it, we explore corporate culture and its relationship to ethics and compliance. The podcasts all post on Libsyn and iTunes on Monday, August 20 at noon, so download them all and binge listen. One of the areas I focused on with Feldman is how a company can begin to assess its own culture.

We began by considering whether a company should try and perform a self-assessment of its own culture or whether it should bring in a truly independent professional to do the assessment. Feldman said that both are valid but each has a different focus. The self-assessment is really more akin to ongoing monitoring. In this scenario, a company has the responsibility to monitor its own workforce and culture literally on a day-to-day basis. He stated, “That ongoing monitoring and oversight is critical to being able to manage what is a very normal ebb and flow of the culture in an organization. Cultures are dependent on people and people come and go in companies and that can influence the culture. The market and financial stress can influence the culture and what happens within a company.” These are all things a company should track and monitor.

When an external independent monitor comes into the picture, a company is able to garner a broader picture of where it’s culture exists. Many employees are more willing to open up to an independent outsider, rather than someone in their own organization. Feldman said that sadly, many leaders do not know their own workforce because they do not interact with them. Such leaders tend to only get filtered information and reports, which do not necessarily represent the true culture or even the way people might feel in their jobs. Such leaders are really relying on hope and not the facts on the ground as they might be presented to an independent, outsider assessor.

Some of the ways to consider the culture of an organization are employee surveys, conversations, visits to field operations. Surveys can be very important tools and take the temperature of what’s going on in the company, but often there is a wasted opportunity there to put in questions that are specifically targeted toward culture and the ethical culture of the company. These need to be two-way conversations to get a true understanding. Feldman said, “often leaders don’t understand how they’re being perceived and whether employees are getting mixed messages.”

Another key area is whether the company has created a true speak up culture. Feldman explained this means “whether there is a comfort level for employees to raise issues, questions or identifying misconduct up through their managers or whether there’s a fear if they do that, they’ll be retaliated against.” This problem can be further acerbated  in organizations where employees do not trust their company. They will tell the company what it wants to hear on surveys, rather than be honest. This means that employee survey results are skewed because employees do not trust the confidentiality of the survey and they are telling the company what they want to hear. That makes it even more challenging to understand what may be going on an organization.

I asked Feldman about multi-national/cultural organizations and if there are differences which must be considered when assessing a global company. He said there can vast culture differences which come into account around the hotlines, reporting and even disrespect of a supervisor. This means one must “fine-tune” a cultural survey to get a good understanding of the company’s culture and obtain meaningful metrics. Feldman further explained that in such situations, there are other metrics you can look at, consider the data and cases of employees coming forward and saying, that “something just doesn’t look right without being anonymous.” Gauging this type of comfort level, in surveys and even focus groups, can be helpful, most particularly if an  external independent third party is involved.

The bottom line is that it is helpful to take the temperature of your employees internally by doing regular monitoring of your company to understand its culture and what needs to be done. However, employees are not going to be as honest and forthcoming with someone in their company as they would be with an independent third-party. This is because employees are almost always afraid of the potential blow back from superiors. Employees will be much more reserved with people that they know or people in their own company so it can be much more powerful and much more effective for an independent third party performing cultural assessment work.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2018

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