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FCPA Compliance Report

FCPA Compliance Report: The Boeing Plea Agreement – Culture is The Key

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. We take things in a different direction today as Tom Fox reposts the recent webinar with Sam Silverstein and Mike Volkov, where we took a deep dive into the Boeing Plea Agreement, the Monitorship, and why culture is the key to a Boeing turnaround.

We explore the recent plea agreement filed by Boeing, the outrage among victims’ families over the proposed penalties, and the appointment of an independent compliance monitor. Key issues discussed include the necessity of a culture overhaul at Boeing, the implications of excluding court jurisdiction over the monitorship, and the role of the board in fostering a culture of compliance and safety. The discussion highlights the critical need to focus on values, accountability, and transparent processes to rebuild trust and ensure long-term organizational integrity.

Highlights of this episode:

  • Details of the Plea Agreement
  • Compliance Monitor Appointment and Transparency
  • The Importance of Culture
  • The Role of Compliance Monitors
  • Board Involvement and Accountability
  • Victims’ Families and Organizational Accountability

Resources:

Sam Silverstein

Mike Volkov

The Culture Audit

Tom Fox

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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

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Sam Silverstein

The Culture Audit™

Tom Fox

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Blog

Transforming a Corporate Culture in Crisis: Lessons from Boeing

There has not been a company that has had a run of worse publicity in 2024 than Boeing. Unfortunately, it has been self-inflicted. I recently participated in a webinar with Sam Silverstein on what Boeing can do to try and pull itself out of the miasma it now finds itself in, which has led to regulatory and criminal scrutiny, critical damage to its reputation, loss of market share, deterioration of its customer relationships, the resignation of its CEO, and destruction of trust within its massive workforce.

The webinar began with a dive into Boeing’s historical mergers, particularly with McDonnell Douglas in 1997, which marked a significant cultural shift within the company. Initially, Boeing was renowned for its high engineering standards, but post-merger, a more bottom-line-focused culture from McDonnell Douglas took precedence. This shift from quality to cost-efficiency laid the groundwork for the issues Boeing faces today.

This consequence of post-merger cultural misalignments led to deep-rooted issues. For Boeing, this resulted in a culture where the drive to reduce costs and increase profitability overshadowed the foundational emphasis on engineering excellence and safety. This cultural shift manifested in various high-profile crises, such as the 737 Max incidents, which were symptomatic of broader systemic problems—problems where the cultural ethos of safety and thoroughness was compromised. Further, when cultural values are misaligned with corporate actions, employee morale, and product quality suffer significantly.

The most important question for Boeing is how it begins a cultural comeback. It all begins with the top leadership, which plays a key role in any cultural transformation. The reason is straightforward: true change starts at the top—leaders must embody the values they wish to see throughout the organization. This involves more than just setting policies; it requires leaders to actively promote a culture of quality, safety, and integrity.

Fortunately, there is a blueprint for Boeing to begin a culture turnaround. It is the procedure that compliance professionals use to manage ethics and compliance risks. The process itself is simple, but execution is not always easy. The process of Assessment leads to Strategy Development, Strategy Implementation, Monitoring of Strategy Implementation, and Continuous Improvement.

With a company the size of Boeing, you need a comprehensive software tool that can assess the corporate culture in a wide variety of ways. Trust, ethics, health, safety, values, beliefs, clarity of mission, quality of decision-making, the value of people, the quality of engagement, accountability, innovation and change, and leadership are but some of the areas that need to be measured in your initial assessment.

In short, you need a tool designed to diagnose and understand your organization’s cultural health. This assessment is not just about identifying weaknesses but also reinforcing strengths. A culture assessment can offer actionable insights that guide strategic change by systematically analyzing various cultural facets—like accountability, ethics, employee engagement, and safety.

Using a software tool to diagnose and understand the current state of organizational culture, you will obtain data about the state of your culture and actionable insights that you can use to form the basis of your comeback strategy. A practical culture assessment can reveal areas of strength to build upon and weaknesses that require strategic interventions. For instance, if there is a deficiency in trust and safety in manufacturing, leadership can clarify that safety is the No. 1 priority. Management can celebrate those who come forward with safety issues in the manufacturing process instead of marginalizing them.

Next is implementing the strategy through training and communications throughout the company. Once again, such an approach is well-known to the compliance community. Further, it is simple but will require effort and commitment by senior management. In 2022, Boeing reported roughly 156,000 employees, representing 47 nationalities in 65 countries around the globe. Yet, think of Siemens’ comeback after its 2008 bribery and corruption scandal. With a similar number of employees around the globe, the company’s top leadership made it clear through in-person training and communications that a change would happen.

Not surprisingly, Siemens management found that employees were sick and tired of being known as a bribery and corruption company. Boeing employees are the same way. They take tremendous pride in working for their organization and will embrace any change to return to the company’s roots of quality and excellence.

Next is the ongoing monitoring of the implemented strategy, which forms an essential component going forward. You cannot simply implement your strategy; you must also monitor the results. Using software tools like the Culture Audit allows companies to gauge their progress and continuously make adjustments where necessary.

You then move to continuous improvement from monitoring. A data-driven approach will allow your organization to provide additional resources, communications, and training where needed. This continuous feedback loop is crucial to maintaining cultural health and aligning it with the company’s strategic objectives.

The lessons from Boeing are applicable globally across industries. Every organization aiming for long-term success must prioritize a culture aligned with its values and objectives. A healthy corporate culture supports a positive internal environment and enhances the company’s reputation and reliability in the eyes of its customers and stakeholders. For companies in cultural crisis, facing their cultural challenges head-on with transparent, actionable strategies offers a path to regain trust and ensure sustainable success. As corporate landscapes continue to evolve, the principles discussed will remain vital for any organization committed to meaningful, enduring change.

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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

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Sam Silverstein

The Culture Audit™

Tom Fox

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Culture Crafters

Culture Crafters – Continual Culture Assessments

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. Rather than simply complying with this mandate, companies should strive to foster their best culture. 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. They discuss the power of continual assessments.

The importance of culture within organizations cannot be overstated; it serves as the backbone for organizational success and growth. Leadership’s power in shaping an organization’s culture requires leaders to live by the values they preach and ensure these values are mirrored in their actions. The existing culture should be continuously assessed through tools like culture audits. Achievements tied to the organization’s unique culture should also be celebrated.

Sam highlights that while all organizations have the potential to build a great culture, successful implementation depends mainly on leadership. He believes a strong, people-centric organizational culture can drive long-term success and growth. He urges the ongoing examination and enhancement of culture to foster a positive, high-performance work environment.

Key Highlights:

  • Cohesive Work Environment for Organizational Success
  • Cultural Audits for Organizational Success
  • The Need for Recognizing Workplace Success and Growth

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

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Culture Crafters

Culture Crafters – A Deep Dive into Culture Assessments

It is always interesting to see the regulators catch up to the business world. 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.

But many business executives and even compliance professionals do not know how to craft a culture that allows your employees and, thereby, 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, look at the ways companies can elevate their culture to new heights.

In this episode, they take a deep dive into culture assessments, highlighting the significance of this process in maintaining effective leadership, employee engagement, diversity, equity, and inclusion.

Comprehensive assessment is a cornerstone for the success of organizations, underpinning their ability to identify weaknesses, implement improvements, and foster a strong ethical culture. Tom and Sam underscore the necessity of a comprehensive assessment for leaders to understand and manage all crucial aspects of their organizations, a neglect of which could be seen as negligence.

They stress the importance of assessment in addressing key areas like stress, diversity, and ethics to attract top talent and boost productivity, profitability, and overall performance. Both advocates believe that without comprehensive assessment, organizations fail their stakeholders and harm their own success and reputation.

Key Highlights

  • Ethical Strength Assessment in Organizational Culture
  • Enhancing Organizational Performance through Comprehensive Assessment
  • Trust-Based Culture Audit for Effective Leadership
  • Foundational Elements for Collaborative Team Success
  • Inclusive Workplace Dynamics for Organizational Success

Resources 

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

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Culture Crafters

Culture Crafters: Assessing Your Culture Through The Culture Audit™

It is always interesting to see the regulators catch up to the business world. That is what has happened around corporate culture. The Department of Justice is now assessing corporate culture for 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. But many business executives and even compliance professionals do not know how to craft a culture that allows your employees and, thereby, 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, look at the ways companies can elevate their culture to new heights.  In this inaugural episode, they discuss how to assess your culture through the Culture Audit™.

The concept of a culture audit is a transformative tool that assesses an organization’s critical areas such as ethics, engagement, accountability, and diversity, offering valuable insights for improvement and fostering a high-performance work culture.

Tom posits that the culture audit not only measures these critical areas but also guides action plans for improvement, emphasizing continual assessment and prioritization of key cultural drivers for genuine change.

Similarly, Sam Silverstein underscores the necessity of conducting a culture audit to discern an organization’s cultural strengths and weaknesses. He asserts that culture directly affects an organization’s bottom line, citing instances where cultural improvements have significantly boosted performance, profits, and employee retention. For Silverstein, a comprehensive culture audit from the boardroom to the shop floor is fundamental for developing a positive and high-performing work environment.

Key Highlights:

  • Enhancing Organizational Culture for High Performance
  • Cultivating Accountability and Excellence for Success
  • Enhancing Workplace Culture through Detailed Assessment
  • Transparent and Traceable Culture Audit Findings
  • High-Performance Culture: Driving Financial Success

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

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Blog

Auditing Culture

Why should you audit your culture? A compliance professional can utilize a comprehensive approach to evaluate various aspects of a company’s culture, including ethics, engagement, accountability, and diversity. Tom Fox and Sam Silverstein took up this topic in the inaugural episode of the Culture Crafters podcast. Silverstein emphasized the pivotal role of a high-performance culture in attracting and retaining top-tier talent, ultimately leading to improved company performance and profitability. According to Silverstein, the shortest and quickest path to organizational transformation is through culture, as it forms the core of all change.

Beginning with the speech by Deputy Attorney General Lisa Monaco in October 2021, they recognized the need for companies to assess, manage, monitor, and improve their corporate culture. This was memorialized in the 2023 Evaluation of Corporate Compliance Programs (ECCP) update, announced in January 2023. In the 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 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 a necessary first step in determining where your culture is, what needs improvement, and how to do so.

As important as it is to meet these DOJ expectations, the real power is to create a high-performing culture to allow your organization to grow to its potential. Focusing on a high-performance culture can lead to an 80% increase in performance, profits, and employee retention, fostering a productive work environment and driving overall success. The bottom line is that a high-performance culture is essential for attracting and retaining top-tier talent and can significantly improve a company’s performance and profitability.

Every compliance professional understands that you must first assess your risks in risk management. When you have assessed a risk, you can start to put together a risk management strategy. The same is true for corporate culture. You must first assess where your culture is and then move forward to improvement through culture and a culture management strategy. 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.

The steps are familiar to every compliance professional.

  1. Assess Every Level. To gain a comprehensive understanding of the company’s culture, you must assess everyone in the organization, not just senior leadership.
  1. Continuous Improvement. After conducting the culture audit, organizations must receive a detailed Culture Audit Report, which includes responses and action plans. This report serves as a roadmap for companies to focus on key drivers, enhance alignment, and continuously improve their workplace culture.
  1. Sustain High Performance. Focus on building a high-performance culture can yield remarkable results, including an 80% increase in performance, profits, and employee retention. Creating a culture that inspires individuals to excel and be accountable is essential for long-term success.

To facilitate this, Silverstein created Culture Audit™. The Culture Audit is a software solution that assesses critical areas of a company’s culture, such as ethics, engagement, accountability, and diversity, providing actionable insights for improvement. Available in over 20 languages, it aids in transforming a company’s culture for sustainable high performance. A high-performance culture is essential for attracting and retaining top-tier talent and can significantly improve a company’s performance and profitability. The Culture Audit Report, a detailed document with responses and action plans, enables organizations to enhance their workplace culture effectively. The audit results are auditable, ensuring accurate conclusions and data traceability, adding credibility to the process. Focusing on a high-performance culture can lead to an 80% increase in performance, profits, and employee retention, fostering a productive work environment and driving overall success.

Silverstein encapsulates the essence of culture transformation: “The shortest, quickest path to seeing transformation in an organization is always through the culture because that’s at the core of all transformation.” Every business is incumbent upon preparing a comprehensive document that takes a deep dive into its culture assessment results and guides it on the path to improvement. This report is a foundation for implementing educational initiatives, training programs, and organizational transformation.

In conclusion, the culture audit is not a one-time fix but a continuous process that requires regular assessment and improvement. By prioritizing a high-performance culture, companies can create a productive work environment, attract top talent, and drive overall success.

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Blog

Assessing and Improving Corporate Culture Through the Culture Audit™

I am hugely pleased to announce a dynamic new tool for compliance professionals, the Culture Audit™ which is a software tool designed to help companies evaluate their corporate culture and identify areas for improvement. Developed by Sam Silverstein, founder of the Accountability Institute, the Culture Audit™ allows a compliance professional or any business to assess their corporate culture quickly and efficiently as mandated by the Department of Justice (DOJ). (Full disclosure-I do work for and with Sam Silverstein and the Accountability Institute.)

Beginning with the speech by Deputy Attorney General Lisa Monaco in October 2021, the recognized the need for companies to assess, manage, monitor and improve their corporate culture. This was memorialized in the 2023 update to the Evaluation of Corporate Compliance Programs (ECCP), announced in January 2023. In the ECCP, the DOJ asks these 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 their culture, because the DOJ is going to do in any enforcement action or review. However, it can be done using the same compliance processes currently in place, as culture is just like any other risk. As a risk, it can be assessed. This is why the Culture Audit™ is such a game-changer in compliance as it provides you a software tool to perform that initial risk assessment. When you have assessed a risk, then you can start to put together a risk management strategy in place. With your culture strategy in place, you can train your employees on it and then monitor their performance, determining the results. From there you can improve your culture strategy as needed. But it all starts with a culture assessment, and that’s what the Culture Audit™ allows you to do.

The Culture Audit™ can be set to 20 languages, which makes this the best possible tool, not just for international companies, with offices around the world, but also those in places like in South Dakota, where there might be a production facility and there could actually be three or four languages spoken on the production floor. This allows all employees in an organization the opportunity to communicate, to provide the vital feedback, and makes this a very powerful tool.

The Culture Audit™ is simple for all employees to use as a link is provided used throughout the organization. Moreover, it is an anonymous survey. The Culture Audit™ does collect any specific Personal Identifiable Information (PII). The Culture Audit™ does not know who is responding, and there is no ability to track back to individual employees. This provides an environment where employees are free to share what they really think about the organization, what they really feel about what’s happening inside in their workplace culture.

The Culture Audit™ measures various aspects of a company’s culture, including compliance practices, hiring processes, and employee engagement. It generates a comprehensive report that highlights gaps and provides actionable steps for improvement. The tool is particularly beneficial for global organizations as it supports international language communication.

One key feature of the Culture Audit™ is its emphasis on auditability and transparency. In the event of a regulator’s inquiry, the Culture Audit™ provides a detailed report that can be shared to demonstrate the company’s commitment to assessing and improving its culture. The questions and the results are fully auditable. The raw data collected during the audit is also retained for future reference, allowing organizations to track their progress over time.

One of the key benefits of the Culture Audit™ is its ability to identify areas for improvement and provide actionable insights. The Culture Audit™ report includes an action plan that guides organizations on specific areas to focus on and steps to take for improvement. Silverstein emphasized that all companies should be either improving because they are underperforming or reinforcing what they are already good at. By continuously reinforcing positive aspects of their culture, organizations can prevent a decline over time.

The Culture Audit™ can also be a valuable tool for companies considering acquisitions. By using the tool to assess the culture of a potential target, companies can gain insights into the target’s values, ethics, and decision-making processes. This information can help inform the decision-making process and identify potential risks or areas of alignment.

The Culture Audit™ is a true game-changer in compliance as it provides organizations with a powerful tool to assess and improve their corporate culture. By measuring various aspects of culture, providing actionable insights, and emphasizing auditability and transparency, the Culture Audit™ helps organizations create a positive and productive workplace environment. With the increasing focus on corporate culture by regulators, the Culture Audit™ 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.

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Culture Audit

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31 Days to More Effective Compliance Programs

The Culture Audit


What is organizational culture? Eric R. Feldman, SVP at Affiliated Monitors Inc. (AMI), has said it comprises the mission, vision and values of an organization. A similar way to consider it might be as a company’s values, visions, norms and beliefs. Whichever way you define it or look at it, corporate culture affects how groups within a company interact with each other. A key inquiry is whether the corporate incentive structure supports the articulated beliefs of a company. How does one measure or audit these articulations?
Companies must have a high-performance corporate culture for doing business ethically. One of the ways to do so is through the culture audit. It can also be a powerful tool for continuous improvement going forward. Find out what your employees are saying about your corporate mission, vision and values and most importantly remediate if those mission, vision and values are found wanting.
 Three key takeaways:

  1. What are the mission, vision and values of a company?
  2. What are the compensation and promotion incentives in the culture?
  3. Is your motto “Always be closing” or closer to “doing business ethically and in compliance”?