Katherine Bradshaw: Showing outcomes promotes a Speak Up culture
Tuesday, December 5, 2017 at 7:28AM
Katherine Bradshaw in Institute of Business Ethics

Communicating the outcomes of investigated cases will encourage confidence in the Speak Up process. But how far can and should companies go in discussing internal failures and describing how raising concerns promptly avoided greater damage occurring?

Lawyers invariably counsel against any form of disclosure, but a new Good Practice Guide from the Institute of Business Ethics provides examples of what some companies are doing in this area.

One of the main barriers to a Speak Up culture is the belief that nothing will be done. In stark contrast to when IBE first asked employees who raised concerns whether they were satisfied with the outcome, the majority now say they are not satisfied -- 61 percent compared with 30 percent three years previously. Publishing outcomes can begin to reframe this narrative and encourage others to speak up.

If an incident has been resolved which was brought to management’s attention by an employee, a case study (suitably anonymized) could be published. This will reinforce the organization’s support and commitment to taking employee concerns seriously and valuing those that speak up.

An example from IBE’s Good Practice Guide is that of BT, the communications company. “We wanted to balance the carrot and the stick, highlighting both positive and negative consequences,” said Laura Reid, Head of Ethics and Compliance Learning and Culture at BT.

“Because we had always dealt with misconduct discreetly, our people couldn’t see that there was a penalty for misconduct -- they didn’t see the action that the organization had taken. We wanted to show our people that our compliance program has teeth,” Reid said.

The company began by talking about the number of disciplinary actions that had been taken and reporting it in the Annual Report. Then they created an article about the data for internal communications. “It was one of our most read articles,” Reid said. “It was evidence of us taking compliance seriously.”

As time went on, BT got better at looking at misconduct categories and the data got richer. “This laid the foundation for us to talk about individual, anonymized cases,” Reid said. The challenge was how to handle them sensitively. “The postcard framework makes them quick and easy to read and being brief it allows us to focus on the behavior and how it relates to our ethics code without going into detail.”

Titled Ethics in action, each postcard outlines two real BT situations and their outcomes -- one positive and one negative -- where appropriate, what action was taken, what the company has learnt and what The Way We Work (BT’s code) says about the issue. HR and Legal are consulted, but the stripped-back content hasn’t created any problems. They are shared on the intranet and via the company’s newswire. Local leaders are also encouraged to communicate them locally if relevant to their area.

“The postcards help to reassure our people and provide positive reinforcement,” Reid said. “It’s about transparency, risk mitigation and, most importantly, doing the right thing.”

Communication of a Speak Up policy and procedure alone will not foster trust. That will only come when employees can begin to see the positive outcomes of raising concerns.


Katherine Bradshaw is Head of Communications at the Institute of Business Ethics. She's the the author of five IBE Good Practice Guides, the most recent of these being Encouraging a Speak Up Culture. She developed the IBE's e-learning tool Understanding Business Ethics, a 30-minute course to sensitize employees to recognize and deal with ethical dilemmas. She can be contacted here.

Article originally appeared on The FCPA Blog (http://www.fcpablog.com/).
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