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  1. Implementing Ethics in the Workplace: Creating the Process(Abridged version)a program of the Greater Omaha Business Ethics Consortiumat Creighton University Sponsored by

  2. The Seven Sentencing Guidelines 1. Having Standards 2. Assigned Responsibility - Adequate Resources 3. Due diligence in Hiring 4. Communications and Training 5. Monitoring, Auditing, Reporting 6. Promotion and Enforcement of Ethical Conduct 7. Reasonable Steps to Prevent Misconduct

  3. The Challenge is Doing More with Less 1. Have a Plan - preferably a long range plan 2. Have support at the Top and an “Ethics Team” 3. Get an Ethics/Compliance Committee Chartered 4. Put in place a “Code of Conduct” 5. Get a Helpline Set Up 6. Communicate to Managers/Employees 7. Do Some Training - E-Mail,Web,Video, 8. Attend Other Meetings or Training Sessions 9. Give Leaders Ethics Messages to Send Out 10. Use the Company Website Extensively 11. Follow in the Wake of Critical Events 12. Regularly Report on Numbers, Issues to Mgt.

  4. Every Company is Unique Leadership History Culture Policies Practices People Regulatory Environment

  5. Gallup Organization FindingsTone at the Top VALUESOne of the Seven Demands of Leadership

  6. Gallup Research Based Findings During nearly forty years of research and tens of thousands of interviews, Gallup has determined the Seven Demands of Leadership. These are behaviors of individuals who are perceived as leaders within their organizations, communities and nations. GOBEC www.omahaethics.org

  7. WHAT GREAT LEADERS DO MOST - the most commonly expressed demandsGallup Organization VISIONING 7 D E M A N D S MENTORING BUILD ACONSTITUENCY CHALLENGINGEXPERIENCES MAKING SENSE OFEXPERIENCES STABILIZINGVALUES KNOWINGSELF GOBEC www.omahaethics.org

  8. Allocation of Time For Creating Alignment Gallup Organization Typical 90-100% 0-5% 0-5% Identifying Core Values Drafting & Redrafting Statements Creating Alignment Desired 10-20% 0-5% 80-90% Drafting & Redrafting Statements Identifying Core Values Creating Alignment GOBEC www.omahaethics.org

  9. Organization and Personnel

  10. How to Manage Organizational Ethics? 1. Create a formal program w/resources 2. Put someone in charge of it • General Counsel • HR director • Internal auditor GOBEC www.omahaethics.org

  11. Report to… • CEO • Board of Directors • Committee of the Board of Directors • Senior Executive GOBEC www.omahaethics.org

  12. Support for Managing Organizational Ethics Programs Ethics and Compliance Officer Association http://www.theecoa.org/ GOBEC www.omahaethics.org

  13. Compliance with Laws Ethical Behavior SWEET SPOT Compliance and Ethics Program

  14. BCBSNE Compliance Organization Board of Directors Audit & Compliance Committee Corporate Compliance Officer (VP Level) Compliance Department (with dedicated Staff) Compliance Cross Functional Team Members GOBEC www.omahaethics.org

  15. Responsibilities Provide Guidance and Answer Questions Create and Assist in Creating Policy & Procedure Develop and Deliver Training Foster Awareness & Encourage Ethical Behaviors Respond to Auditors and Regulators Respond to Complaints (Receive/Investigate/Document/Resolve) Liaison with the Board of Directors Listen Report Keep Current on and Facilitate Compliance with Laws and Regulations GOBEC www.omahaethics.org

  16. Communication & Training Getting the right message out

  17. What is communicated? GOBEC www.omahaethics.org

  18. Methods of Communication Evaluate current ethics communication lines • Formal and informal • downward, upward, and two way Clear, consistent, credible messages across communication lines GOBEC www.omahaethics.org

  19. More about Methods of Communication • Hiring Announcements • Website • Email • Brochures • Meetings – Formal & Informal • Orientation sessions • Newsletters • Manuals • Code Handbooks w/certifications • Badges and Wallet Cards • Key Fobs GOBEC www.omahaethics.org

  20. Ethics Training Design for individual groups Groups: • new recruits • existing employees • top management • local management GOBEC www.omahaethics.org

  21. Ethics Training • Live • Computer based • Trainers • Certification GOBEC www.omahaethics.org

  22. Helplines/Hotlines Getting Started, Outsourcing, Case Management, Operational Flow, Processes, and more Factors and Features

  23. Introduction • What – is a helpline/hotline and what do you need to do to establish one? • Why – set up a helpline/hotline? • Who – should answer the line? • How – does a helpline/hotline work? • When – can you expect to fully implement a helpline/hotline? • Free Advice –vendor selection, positioning, themes, questions GOBEC www.omahaethics.org

  24. What…. A Helpline/Hotline Is and Some Alternative Reporting Mechanisms • Helpline…. a confidential toll-free telephone number for employees or others to report suspected violations of law or company policy and to answer policy questions • Hotline – focuses on the reporting of suspected violations and emergencies • Consider departmental needs/requirements (Safety, EEO, Audit, Environmental, HR) • Evolution of reporting channels • From post office boxes • To confidential faxes • To voice mailboxes • To confidential e-mails • To web-based reporting systems GOBEC www.omahaethics.org

  25. What …. You Need to Establish a Helpline • Senior Management Support and some Money • Understandable Guidelines for using the Helpline that Reflect your Organizational Values and Policies • Multi-function support (Communications, HR, IT, Law, EEO, Operating, Audit, etc.) • Designated Support Personnel • Accountability and follow-up • Communications and Employee Awareness GOBEC www.omahaethics.org

  26. Union Pacific’s Values Line • Established in 1994 and is outsourced (third-party service) • Covers 55,000 employees • Is a “business conduct” report line • Does not primarily support Safety, Emergencies, Environmental, Payroll or HR services (internal lines) • Supports EEO, Audit, Policy and Employee Relations reporting GOBEC www.omahaethics.org

  27. Why….Set up a Helpline or Hotline? • Understand the objectives • Increased emphasis on organizational ethics and compliance– carrot and stick incentives • Establish formal monitoring, auditing and reporting systems • Provide anonymous channel for reporting suspected violations (which may otherwise be unreported) • Raise awareness of commitment to ethical conduct • Establish a proven, effective tool for protecting company GOBEC www.omahaethics.org

  28. Why… Set up a Helpline or Hotline? Legal and Regulatory Requirements • Federal Sentencing guidelines – One of seven steps in an effective ethics and compliance program • SEC implementing rules • New York Stock Exchange proposed listing requirements • Sarbanes-Oxley Act (enacted 2002) • Sections 301 and 806 GOBEC www.omahaethics.org

  29. External 24/7/365 Anonymity Multilingual Perceived confidentiality Vendor Features Internal Staffing/budget Time constraints Employee trust Knowledge of Policies Translation services? Training/Turnover Software Who …. should answer the line?Decision Process GOBEC www.omahaethics.org

  30. Who?….Analyzing Vendors • Vendor Selection Process • Talk with people who have lines • Visit Vendor Websites • Review intake process/procedures • Request proposals, review best practices • Include your IT department • Perhaps absorb existing call system(s) • Consider hidden costs, extra reporting GOBEC www.omahaethics.org

  31. How…. Does a report line work? - Call is placed to the UP Values Line designated toll-free number (800-998-2000) OR shared toll-free number • Helpline personnel records information according to general protocol or your specific design (EEO, FMLA, etc.) • Classifications, information, key issues • Case is reported to you and/or others via e-mail or web links • Case management data is summarized each month or through ad hoc reports GOBEC www.omahaethics.org

  32. Operational Key Points • Spread Out the Work • Expect 1-2% of Employees to call/yr • Who Calls the Line? • Types of Calls, Categories • Anonymous versus Identified (20/80) • Sufficient Investigation Resources • No Retaliation for good faith reporting • Confidentiality to extent possible • Follow up is essential GOBEC www.omahaethics.org

  33. GOBEC www.omahaethics.org

  34. Questions? • Cost – $1,500 to $30,000+ per year+ your time • Reports – see handouts • Vendors – The Network, EthicsPoint, Lighthouse, • Allegiance, and many more. • See handouts of hotline best practices • Helping to maintain a culture of integrity GOBEC www.omahaethics.org

  35. Enforcement Ensuring Observance Putting into practice Making it happen

  36. Enforcement • Reality: Codes and rules without enforcement and adherence are useless. • Question: How do we ensure compliance with legal rules and corporate policies? GOBEC www.omahaethics.org

  37. Why should you enforce? You have Two Choices: • Corporate Enforcement • Government Enforcement • The best enforcement is self-enforcement! • Better your company do it than the EEO, SEC, IRS, court, etc. GOBEC www.omahaethics.org

  38. Types of EnforcementThe best policy is to prevent wrongdoing • Getting Compliance (preventative) • Training and Education (‘I didn’t know’) • Review: Audit for compliance and quality • Incentives: compensation and recognition • Model: Leadership talks, and walks the talk • Punishment (responsive) • Clear Sanctions in place • Ethics Committee (method in place) • Someone with oversight responsibility GOBEC www.omahaethics.org

  39. Implementing Enforcement • Consistency is Important across Firm • Cross-check from HR for termination issues • Codified Policy is helpful • Yet, Flexibility is important also • Realize Firing is sometimes correct action for sake of firm. • Unions usually have process/expectations GOBEC www.omahaethics.org

  40. Correcting Problems • Sentencing Guidelines also require that you have a method of remedying ethical problem areas in your corporate culture • Examples: • Ethics committees • Ombudsman • Ethics Officer • Stated Corporate Policy On Correction Procedure GOBEC www.omahaethics.org

  41. The Seven Sentencing Guidelines 1. Having Standards 2. Assigned Responsibility - Adequate Resources 3. Due diligence in Hiring 4. Communications and Training 5. Monitoring, Auditing, Reporting 6. Promotion and Enforcement of Ethical Conduct 7. Reasonable Steps to Prevent Misconduct

  42. Wrap Up Discussion GOBEC www.omahaethics.org