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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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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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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”?