Middle managers are some of the most important members of your compliance and ethics team. Research shows that employees are more likely to report concerns about misconduct to their direct manager or supervisor rather than use a hotline. Eric discusses this data more specifically in “What can you do to prevent retaliation and encourage employees to report retaliation?” and “Why does no one call the helpline?”. Giving managers the resources to be effective leaders and engaging managers in your compliance and ethics program is one of the best ways to prevent compliance failures.
Many managers are already involved in one area of training. They are often charged with overseeing their reports’ completion of computer-based training. This can be a fairly rote exercise in which managers remind employees to complete training. Managers should really have a more proactive role in training and communication about compliance and ethics issues in order for you to maintain an effective compliance and ethics program.
In this episode, Eric discusses three ways to engage managers. Managers need to become trainers in your compliance and ethics program. Online training is hard to beat when you must train hundreds or thousands of employees on the same issues. But online training shouldn’t replace live training. In live training, there is a give and take that more effectively teaches employees about risk topics. This simply can’t be replaced by online training. Eric tells you simple ways to give managers the tools to be effective trainers and to create a manager-training program that is simple to implement.
Managers also need to be part of your continuing communication around compliance and ethics issues. Communication is one of the Sentencing Guidelines Seven Hallmarks of an Effective Compliance Program. We often talk about training and communication together, but they should be two distinct parts of your program. Training encompasses those formal courses. Communication is more informal and more frequent. Eric discusses easy ways to give managers the resources to engage their reports in these discussions around risk topics and other compliance and ethics issues on a regular basis.
Even more broadly than compliance, you should help your managers engage in team building. Encouraging managers to implement policies, such as open-door policies, that good rapport and open discussions with their reports will help create an environment where managers can be more effective in training and communication. Eric talks about ways that to create an environment where people talk frequently and are encouraged to come forward to talk about issues before there’s a compliance failure.
If you are looking for ways to involve your managers in your compliance and ethics program, three places to start are engaging managers in training, giving managers tools to engage in regular communication about compliance and ethics issues, and helping managers build strong teams and good rapport with their direct reports.
Three Questions with Gretchen Winter, Executive Director, Center for Professional Responsibility in Business and Society at the College of Business at the University of Illinois at Urbana-Champaign
Gretchen is well known figure in the field of compliance and ethics. As the Executive Director of Center for Professional Responsibility in Business and Society at the College of Business, Gretchen also serves as a Visiting Professor at the Universite de Cergy-Pontoise School of Law, an Adjunct Professor at the University of Illinois College of Law, and as faculty for a University of Illinois College of Business class on professional responsibility and business ethics. She teaches in educational programs for NYSE Governance Services, Thomson-Reuters, the Society of Corporate Secretaries and Governance Professionals, the Ethics and Compliance Initiative, the Practising Law Institute, and the Society of Corporate Compliance and Ethics. Gretchen started her career at Baxter International, Inc. She worked for 18 years at Baxter, serving for more than a decade as Vice President and Counsel, Business Practices. Gretchen developed the company’s global ethics program and provided guidance to those who saw ethical dilemmas in their work. Eric and Gretchen discuss the importance of compliance and ethics education in law school and business school, advice for those starting a career in compliance and ethics, and future trends in compliance and ethics.