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FCPA Compliance Report

FCPA Compliance Report: How Boeing Can Make a Cultural Comeback

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance.

In this special edition of the FCPA Compliance Report, welcome Sam Silverstein. They take a deep dive into how Boeing can begin to overhaul and reform their toxic culture, which led to the 2024 compliance and ethics failures. They discuss the power of the Culture Audit™, which is the sponsor of this podcast.

Sam Silverstein is a seasoned professional with over three decades of experience in corporate culture. Silverstein believes that a strong leadership role is crucial in driving culture change within an organization. His philosophy is that action follows belief, stressing that leaders must genuinely prioritize creating a culture of quality, compliance, and safety for it to truly thrive.

Silverstein maintains that the CEO’s primary role is to protect the organization’s culture, while the COO should ensure operations align with the board and CEO’s strategic plan. His experiences, particularly his insights drawn from Boeing’s situations, have shaped his belief that prioritizing culture over short-term profits, along with a culture audit and specific implementation plan, can help address systemic issues and foster a high-performance workplace culture. 

Topics Covered in This Episode:

  • Transition from Safety to Profit Culture at Boeing
  • Measuring Organizational Culture through Employee Engagement
  • Creating Accountable Leaders for Organizational Culture Transformation
  • Cultivating Sustainable High-Performance Organizational Culture
  • Cultivating Employee Trust Through Genuine Leadership Efforts
  • Rewarding Ethical Behavior for Organizational Integrity
  • Data-Driven Organizational Culture Enhancement Process
  • Recognition and Amplification through Personalized Engagement

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

 

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: Getting Culture Right, Part 2

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we begin a two-part exploration of 10 steps to getting culture right, with Steps 6–10.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

Categories
Compliance Tip of the Day

Compliance Tip of the Day: Getting Culture Right, Part 1

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we begin a two-part exploration of 10 steps to getting culture right, with Steps 1–5.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

Categories
Compliance Tip of the Day

Compliance Tip of the Day: The Importance of Culture

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we note how the DOJ has elevated the importance of corporate culture and ask what you have done to meet this new requirement.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Culture Crafters

Culture Crafters – How to Repair the Broken Culture at Boeing

Seeing the regulators catch up to the business world is always interesting. That is what has happened to corporate culture. The Department of Justice is now assessing the corporate culture of any company under investigation. Yet, more than simply complying with this mandate, companies should strive to foster the best culture they can. The reason is deceptively simple: the better the culture, the better the company. However, many business executives and even compliance professionals do not know how to craft a culture that allows your employees and your organization to implement such strategies. How can you unlock the power of a thriving workplace culture?

In this podcast series, Sam Silverstein, the most trusted voice in America on accountability, and Tom Fox, the Voice of Compliance, discuss ways companies can elevate their culture to new heights. This episode examines the current Boeing scandal from a cultural angle.

The recent FAA report on Boeing has shed light on a worrying culture of fear, inadequate training, and mistrust within the company, leading to compromised safety standards. Tom points to management and cultural issues as the root causes of these safety failures. He insists that Boeing needs to foster a culture of safety, transparency, and open communication, without which it cannot rectify its current predicament. Sam emphasizes leadership’s crucial role in shaping a safe and open culture, arguing that leaders must take responsibility for any existing fear or retaliation. Drawing on his extensive experience advising leaders on accountability, Silverstein believes in the necessity of a culture where employees feel valued and can voice their concerns, suggesting that tough love may be the key to navigating Boeing’s safety issues.

Key Highlights:

  • Boeing’s Culture Impacts Safety Standards
  • Encouraging Safety Concerns Through Open Communication
  •  Leadership’s Role in Shaping Organizational Culture
  • How can Boeing start to rebuild its culture?

Resources 

Sam Silverstein

Sam Silverstein is on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Blog

How Boeing Can Begin to Fix its Broken Culture

How bad is Boeing’s culture? It is so bad that, as reported in the WSJ, the CEO has announced his departure from the company, and the Chairman of the Board of Directors has announced he will not stand for re-election. It is so bad that the New York Times asked in a headline, What Should Boeing Do to Fix Its Longstanding Problems? Over this week, I have been exploring how a company can assess its corporate culture, improve it, and make those changes permanent through continuous monitoring and improvement. I want to conclude this blog post series by applying those lessons to the current culture at Boeing.

First, Boeing must create a culture that prioritizes those who speak up about safety issues. An organization’s speak-up culture is essential for fostering open communication, transparency, and employee trust. Such a culture encourages individuals to raise concerns, flag potential issues, and contribute to a safer and more accountable work environment. By prioritizing a speak-up culture, companies can proactively address challenges, prevent safety risks, and promote a culture of continuous improvement.

A speak-up culture is a critical factor in ensuring organizational success and safety. Employees must feel safe, valued, and empowered to voice their opinions without fear of reprisal. Boeing must create a culture of trust and psychological safety to enable individuals to speak up, as a culture that supports open communication leads to better decision-making processes and overall performance. A speak-up culture is pivotal in shaping a positive and proactive organizational environment.

Accountability in leadership is fundamental to setting the tone for organizational culture and fostering a sense of responsibility and integrity among team members. The resignation of the CEO is probably a necessary first step, as leaders who demonstrate accountability not only model desired behaviors but also create a culture where individuals take ownership of their actions and outcomes. Leaders cultivate a culture of trust, respect, and ethical conduct by holding themselves and others accountable for their commitments and decisions. Such leadership is lacking at this point at Boeing.

Sam Silverstein has emphasized accountability in leadership as a transformative impact on organizational dynamics. By stressing that accountability is a way of life rather than a mere task, Silverstein underscored leaders’ profound influence in shaping the values and norms within their teams. He stressed the importance of consistency and fairness in holding individuals accountable, noting that leaders play a pivotal role in setting expectations and driving cultural change. The discussion underscored the critical role of leadership accountability in fostering a culture of integrity and excellence within organizations.

Yet the question remains: How can Boeing change its corporate culture? Changing organizational culture is a complex and multifaceted endeavor that requires a deliberate and strategic approach. To shift its culture, Boeing must first assess the existing norms, values, and behaviors that shape its environment. Boeing can begin by identifying areas for improvement and aligning cultural practices with desired outcomes. Companies can embark on a journey of cultural transformation that enhances employee engagement, performance, and overall organizational success. It all starts with a cultural assessment.

Equally important is the need for the new CEO and Boeing’s senior leadership to fully commit to driving cultural change within organizations. Boeing can initiate meaningful change by defining and measuring the current culture, investing in training and education, and holding individuals accountable for upholding cultural values. Cultural initiatives must be aligned with business objectives and ensure that cultural transformation efforts are embedded in every aspect of the organization. There are significant challenges ahead for Boeing, but the company has the opportunity to achieve lasting transformation.

In short, the company must take the following steps:

  • Analyze its safety failure report to uncover critical insights into safety management protocols and potential areas for improvement.
  • Explore the profound impact of company culture on safety practices and understand how it shapes employees’ behavior and decision-making in critical situations.
  • Implement effective speak-up programs to empower employees to voice their safety concerns without fear of reprisal, fostering a culture of open communication and proactive risk mitigation.
  • Foster safe environments by leveraging leadership’s pivotal role in setting clear safety expectations, modeling best practices, and promoting a culture of accountability.
  • Enhance reporting systems in large corporations to streamline incident documentation, analysis, and communication for proactive risk management and continuous safety improvement.

I hope you have enjoyed this blog post series on corporate culture and that you will follow my latest podcast, Culture Crafters, on the Compliance Podcast Network.

Categories
Blog

Sustaining Culture: Continually Improve Company Culture

What’s measured is treasured. If it is important, you want to know what is going on and improve on it. And it’s data; it’s factual. And so right away, we know what to do, and we can see the improvements we’re making because we can measure and improve them. Sam Silverstein.

I am in the middle of premiering a new podcast series, Culture Crafters, on the Compliance Podcast Network. In this series, together with Sam Silverstein, we are taking a deep dive into corporate culture: how to measure it, assess it, monitor it, and improve it. Through this exploration, we have uncovered the surprising truth behind sustained success in company culture. We have taken a deep dive into maintaining a high-performing culture that attracts and retains top talent. We have discussed the often overlooked strategy that propels companies to celebrate every win, big or small, and compound their growth year after year. Today, we continue our journey by considering why you should continuously audit and assess your culture to improve it.

Achieving and sustaining a great culture within organizations is foundational to long-term success. It involves creating an environment where individuals feel valued and motivated to contribute meaningfully towards shared goals. This process starts with leadership setting the tone by exemplifying behaviors prioritizing people’s well-being and professional growth. Leaders can inspire employees to engage fully and commit to the organization’s vision by fostering a culture of trust, respect, and open communication. Consistently reinforcing core values and recognizing contributions are key components in nurturing a positive culture that endures challenges and fosters innovation.

Regular culture audits are essential for organizations seeking to understand and improve their cultural dynamics. These assessments provide a baseline for measuring progress and identifying areas for growth. By gathering data on employee perceptions, engagement levels, and alignment with organizational values, companies can pinpoint strengths and weaknesses within their culture. This information allows leaders to tailor interventions, policies, and initiatives that align with the organization’s desired cultural outcomes.

Moreover, ongoing assessments enable organizations to adapt to changing circumstances and ensure that the culture remains aligned with evolving goals and external influences. Sam Silverstein’s discussion on culture audits highlights the value of using data-driven insights to inform decision-making and drive cultural improvements. He stresses the importance of combining qualitative feedback with quantitative metrics to understand the organization’s culture comprehensively.

By being transparent about assessment results, leaders can foster a culture of accountability and continuous improvement. Sam’s emphasis on the iterative nature of culture assessments underscores the need for organizations to view cultural dynamics as dynamic and evolving. The conversation underscores that continual assessment is not merely a one-time exercise but a strategic tool for maintaining a healthy and adaptive culture over time. You should develop a plan to assess and regularly improve your culture.

  • Culture Audit: Develop a culture audit to assess the current state of your company’s culture. This can help identify areas for improvement and set a baseline for future assessments.
  • Documentation: Document your culture assessment findings and improvement plans. Utilize tools to create and maintain detailed records of your culture assessment and improvement initiatives.
  • Regular Assessment: Implement a schedule for culture assessments, such as quarterly or bi-annually. Use tools to gather feedback and measure progress over time.
  • Celebrate: Incorporate a culture of celebration within your organization. This can include employee recognition programs, town hall meetings, or even small gestures like personalized notes or tokens of appreciation.
  • Continuous Improvement: Based on the results of your culture assessments, develop a plan for continuous improvement. Use project management tools like Asana, Trello, or Monday.com to track and execute improvement initiatives, ensuring that progress is ongoing and continuous.

The bottom line is that authentic leadership plays a pivotal role in shaping a thriving culture. Compliance professionals and business leaders go beyond superficial gestures and genuinely prioritize the well-being of their teams. Leaders can create a culture where individuals feel respected and valued by demonstrating care and investment in employees’ development. Key traits include actively listening to employee feedback, providing growth opportunities, and demonstrating ethical decision-making. Ultimately, the conversation reveals that sustained success in company culture hinges on leaders’ commitment to prioritizing people and consistently reinforcing a positive work environment.

Categories
Blog

The Ultimate Guide to Culture Assessment

Assessing an organization’s various aspects is crucial for its success. From ethics to workplace dynamics, leaders need to consider multiple factors to create a transparent and efficient work environment—in short, a better culture. In this blog post, we will explore the importance of assessing ethics, speed of implementation, trust, stress, diversity, equity, and inclusion in organizations.

Why should an organization prioritize assessing ethics, speed of implementation, and trust for organizational success? Of course, there is the regulator aspect, as exemplified by Deputy Attorney General Lisa Monaco in October 2021, who recognized the need for companies to assess, manage, monitor, and improve their corporate culture. Her vision was then memorialized in the 2023 Evaluation of Corporate Compliance Programs (ECCP) update, announced in January 2023. In the ECCP, the Department of Justice (DOJ) asked the following questions: How often and how does a company measure a culture of compliance? What are your hiring and incentive structures around compliance? What steps have you taken in response to your measurements of compliance? Yet the more compelling reason is the business basis for corporate culture.

A successful culture assessment involves assessing various areas of an organization’s culture to shape a solid, high-performing environment. The assessment should focus on values, ethics, mission clarity, employee engagement, trust, and communication to identify areas of strength and improvement. By optimizing the process, compliance professionals can gain valuable insights that guide them in creating a culture that fosters integrity, collaboration, and superior performance.

Assessing culture within an organization is crucial for maintaining a positive reputation and building trust with stakeholders. It ensures that the organization operates with integrity and follows ethical guidelines in all its practices. Speed of implementation is also important, as it allows organizations to adapt quickly to changing market conditions and stay ahead of the competition. On the other hand, trust is the foundation of any successful organization. Building trust among employees, customers, and partners creates a positive work environment and fosters collaboration and innovation. To prioritize these aspects, leaders can set clear ethical guidelines, streamline processes for faster implementation, and actively work on building trust through open communication and transparency.

What role do stress, diversity, equity, and inclusion play in evaluating workplace dynamics and your organization’s culture? Stress can significantly impact workplace dynamics, affecting employee morale, productivity, and overall well-being. Organizations need to assess and address workplace stress sources to create a positive and supportive environment for employees. Diversity, equity, and inclusion are key factors in evaluating workplace dynamics. A diverse and inclusive workforce brings different perspectives and ideas, leading to better decision-making and innovation.

To address stress in the workplace, leaders can offer resources for mental health support, promote work-life balance, and create a culture of open communication. To foster diversity, equity, and inclusion, organizations can implement diversity training programs, establish inclusive hiring practices, and create opportunities for underrepresented groups to thrive.

One area that compliance professionals do not talk enough about is trust. Trust is the cornerstone of any successful organization. It creates a foundation of respect, collaboration, and teamwork among employees, leading to increased productivity and job satisfaction. Trust also fosters organizational transparency, allowing for open communication and accountability at all levels. To build trust in the workplace, compliance professionals and, indeed, all business leaders must lead by example, communicate openly and honestly, and establish a culture of trust and respect. By prioritizing trust, companies can create an environment where employees feel empowered and motivated to perform at their best.

A culture assessment helps organizations create a positive and productive workplace environment by measuring various aspects of culture, providing actionable insights, and emphasizing audibility and transparency. With regulators’ increasing focus on corporate culture, a culture assessment can also help companies demonstrate their commitment to ethical behavior and compliance. By utilizing this tool, organizations can drive better leadership, improve employee engagement, and ultimately enhance their bottom line.

Assessing ethics, speed of implementation, trust, stress, diversity, equity, and inclusion are essential to building a successful and sustainable organization. By prioritizing these aspects, compliance professionals and business leaders can create a transparent and efficient work environment that fosters collaboration, innovation, and success.

 If you feel overwhelmed by the complexity of assessing and improving your organization’s culture, then you are not alone. The struggle to identify cultural deficiencies and areas for improvement within the multifaceted aspects of organizational culture can be daunting. It would be best to break free from the overwhelming process and gain the insights you need to enhance your organization’s performance and productivity. Following these precepts will help you uncover the key to unlocking a culture that drives success.

Categories
Culture Crafters

Culture Crafters – What is Culture?

Seeing the regulators catch up to the business world is always interesting. That is what has happened to corporate culture. The Department of Justice is now assessing the corporate culture of any company under investigation. Yet, more than simply complying with this mandate, companies should strive to foster the best culture they can achieve. The reason is deceptively simple: the better the culture, the better the company. However, many business executives and even compliance professionals do not know how to craft a culture that allows your employees and your organization to implement such strategies. How can you unlock the power of a thriving workplace culture?

In this podcast series, Sam Silverstein, the most trusted voice in America on accountability, and Tom Fox, the Voice of Compliance, discuss the ways companies can elevate their culture to new heights. In this episode, they discuss what culture is.

Culture is the organizational DNA that underpins every action and decision, with leaders playing a pivotal role in its creation and sustenance. Tom strongly believes that culture is a top-down approach that commences at the highest echelons and permeates all levels. Fox underscores the power of repeated positive actions in shaping culture and questions how leadership’s cultural focus sets the tone for the rest of the organization.

Similarly, Sam emphasizes that culture reflects what is accepted and repeated within an organization. He advocates for a “culture by design,” a strategic and considered approach that aligns with the organization’s core values and goals. To Silverstein, trust and communication are central to a robust culture, which everyone is aware of and contributes towards maintaining and enhancing.

Key Highlights:

  • Cultivating Trust Through Organizational Leadership
  • Valuing People: The Heart of Leadership
  • Preserving Organizational Culture Through Leadership Succession
  • Cultural Values Upheld Through Individual Responsibility
  • Enhancing Organizational Culture Through Audits

Resources 

Sam Silverstein

Sam Silverstein is on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Blog

Role of Leadership in Culture and Course Correcting

Many people focus on qualities like decisiveness, communication skills, and strategic thinking when it comes to leadership. While these traits are undoubtedly important, another aspect of leadership often gets overlooked: the role of culture. An organization’s culture can significantly impact its success, and leaders who understand and prioritize this aspect can create a more positive and productive work environment. In this blog post, we will explore the importance of culture in leadership and provide practical tips for harnessing its power.

Why is it important to hire leaders who understand and prioritize the existing culture or improve it if needed? Leaders who understand and prioritize an organization’s existing culture are better equipped to make informed decisions that align with its values and goals. By hiring culturally sensitive leaders, you can ensure they will respect and uphold your organization’s unique traditions and norms. Additionally, leaders in tune with the culture are more likely to inspire employee trust and loyalty, leading to higher engagement and job satisfaction.

To hire leaders who understand and prioritize the existing culture, every organization should consider incorporating questions about cultural fit into their interview process for anyone being reviewed and interviewed. Your organization should seek candidates who demonstrate an awareness of your organization’s values and a willingness to embrace its culture. Additionally, new leaders should be provided with training and resources to help them acclimate to the culture and understand how their actions can impact it.

What happens if something goes wrong, and how should your compliance function address behavior that undermines the organizational culture? The most direct, perhaps significant, method is to address behavior that undermines the organizational culture promptly and directly. The reason is that when left unchecked, negative behavior can erode trust, create conflict, and harm employee morale. Compliance professionals should proactively address behavior that goes against the organization’s values by setting clear expectations, providing feedback, and offering support to help employees correct their course.

When addressing behavior that undermines the organizational culture, you should focus on open communication, active listening, and constructive feedback. It is important to address issues as they arise and involve HR, compliance, or other resources to ensure a fair and respectful resolution. With compliance as the herald of Organizational Justice and Fairness, you can see the compliance angle in all these matters. By addressing negative behavior head-on, your organization can communicate that its culture is non-negotiable and everyone is expected to uphold its values.

A culture audit is one of the key ways to determine if your organization needs to correct its course. Implementing cultural audits in an organization can help leaders gain valuable insights into the culture’s current state and identify areas for improvement. By conducting regular assessments of the culture, leaders can track progress, measure the impact of initiatives, and make data-driven decisions about strengthening and promoting the organization’s values. Cultural audits can also help leaders identify potential risks, such as issues related to diversity and inclusion, and take proactive steps to address them.

The Department of Justice (DOJ) has also recognized culture management as a critical element for compliance. Beginning with the speech by Deputy Attorney General Lisa Monaco in October 2021, she discussed the need for companies to assess, manage, monitor, and improve their corporate culture. This was memorialized in the 2023 Evaluation of Corporate Compliance Programs (2023 ECCP) update. In the 2023 ECCP, the DOJ asks the following questions: how often and how does a company measure a culture of compliance? What are your hiring and incentive structures around compliance? What steps have you taken in response to your measurements of compliance?

All these questions posed by the DOJ lead to the requirement that every company needs to assess its culture because the DOJ will take any enforcement action or review. However, it can be done using the same current compliance processes, as culture is just like any other risk. As a risk, it can be assessed. This is why a culture audit is critical for you to perform to ensure your corporate culture is where it should be. When you have assessed your culture, you can start to put together a management strategy to improve and correct your corporate culture. With your culture strategy in place, you can train your employees and monitor their performance, determining the results. From there, you can improve your culture strategy as needed. But it all starts with a culture audit.

To implement cultural audits in your organization, consider working with an external consultant or HR professional specializing in organizational culture. Develop a comprehensive audit plan that includes surveys, focus groups, interviews, and observations to gather data from various sources. Use the insights gained from the audit to develop a strategic action plan to strengthen the culture, address concerns, and foster a positive work environment for all employees.

In conclusion, the importance of culture in leadership cannot be overstated. Leaders who understand and prioritize an organization’s existing culture can create a more positive and productive work environment, inspire trust and loyalty among employees, and drive success. By hiring culturally sensitive leaders, addressing behavior that undermines the organizational culture, and implementing cultural audits, organizations can strengthen their values, build a strong foundation for growth, and create a workplace where everyone can thrive.