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Compliance Tip of the Day

Compliance Tip of the Day: Characteristics of a Toxic 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 consider the 5 top characteristics of a toxic corporate culture.

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 Week: Part 2 – Attributes of a Toxic Corporate Culture

We continue our exploration of aspects of corporate culture. Today, we turn to the dark side by reviewing some of the characteristics of a toxic corporate culture. An article in the MIT Sloan Management Review provided some guidance. In Why Every Leader Needs to Worry About Toxic Culture, Donald Sull, Charles Sull, William Cipolli, and Caio Brighenti posited that, by pinpointing the elements of toxic culture in a company, its leaders focus on addressing the issues that lead employees to disengage and quit. These ideas are essential for compliance as they navigate corporate culture and assess and improve it.

Moreover, the Chief Compliance Officer and corporate compliance function were again identified in the 2023 Evaluation of Corporate Compliance Programs (ECCP) as the institutional justice and fairness keepers. This means recognizing and preventing a toxic culture from spreading and infecting your entire organization, which is squarely in the compliance wheelhouse. The article lays out vital red flags for every CCO and compliance professional to look for in assessing culture. Last but not least, for any company with a toxic culture, the likelihood that its employees will commit fraud or bribe and corrupt others by breaking laws like the Foreign Corrupt Practices Act (FCPA) is much higher.

The authors identify behaviors they call “the Toxic Five attributes,” which are being “disrespectful, non-inclusive, unethical, cutthroat, and abusive—poison corporate culture in employees’ eyes. While organizational culture can disappoint employees in many ways, these five elements have by far the largest negative impact on how employees rate their corporate culture and have contributed most to employee attrition throughout the Great Resignation.” As a CCO or compliance professional, you must be on the lookout for them and take steps to remedy them if you see or hear about them.

Disrespectful Behavior

The authors found that “feeling disrespected at work has the largest negative impact on an employee’s overall rating of their corporate culture of any single topic.” Lack of respect can occur in many areas. The most obvious is the lack of a “speak up” culture where employees understand it is useless to raise issues with management, whether serious matters such as FCPA violations or more straightforward ideas such as process improvement. It can also be as simple as whether to return to the office full-time and whether management listens to employees about their desires to continue working from home or to utilize some hybrid working arrangement. The authors noted, “Whether you analyze culture at the level of the individual employee or aggregate to the organization as a whole, respect toward employees rises to the top of the list of cultural elements that matter most.

Non-inclusive Behavior

This concerns whether your employees are “treated fairly, made to feel welcome, and included in key decisions.” It is “the most powerful predictor of whether employees view their organization’s culture as toxic. It applies to all demographic groups: “gender, race, sexual identity and orientation, disability, and age.” It can be outright discrimination against the equally invidious but more subtle conflicts of interests of nepotism and playing favorites. The topic of non-inclusiveness includes “terms like ‘cliques,’ ‘clubby, or ‘in crowd that indicate that some employees are being excluded without specifying why.

Ethical Behavior

The authors believe ethics “is a fundamental aspect of culture that matters at both the organizational and individual levels. Interestingly, there are several different aspects of “ethics that every CCO needs to consider. Unethical behavior is “about integrity and ethics within an organization. It also includes dishonesty. “Employees described dishonest behavior in many ways, from outright lying to making false promises to shading the truth to simply “sugarcoating. Under regulatory compliance, employees talked about failure to comply with applicable regulations, including failure to meet safety standards.

Cutthroat Behavior

I found this category fascinating as it included both uncooperative coworkers and the lack of harmonization across organizational silos. This was not simply “friction in coordination, but situations in which “employees talked about colleagues actively undermining one another. It included what the authors termed as a “vivid lexicon to describe their workplace, including ‘dog-eat-dog and ‘Darwinian and talked about coworkers who ‘throw one another under the bus,‘ ‘stab each other in the back, or ‘sabotage one another.'”

Abusive Behavior

Having worked in law firms long ago, I understand abusive behavior. The authors called it “sustained hostile behavior toward employees, including “bullying, yelling, or shouting at employees, belittling or demeaning subordinates, verbally abusing people, and condescending or talking down to employees. While one would hope such behaviors do not exist in the 21st century, they still do. The article’s authors reported that only 0.8% of the employees surveyed described their manager as abusive. However, when employees did mention abusive managers, it significantly depressed the corporate culture.

What CCOs and compliance professionals should try to drive forward is a “culture that is inclusive, respectful, ethical, collaborative, and free from abuse by those in positions of power. However, the authors caution that these are the “baseline elements of a healthy corporate culture. Employees want more than the basics; other organizational stakeholders want companies to have official, solid core values. In an interview with LRN’s Susan Divers, she called this emphasis on core values the “value in values.” From the compliance professional’s perspective, it means values like integrity, collaboration, respect, and DEI.

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Blog

Culture Week: Part 1 – Redesigning Culture

In the FCPA Compliance and Ethics Blog this week, I will explore corporate culture from various angles. Since at least October 2021, the Department of Justice (DOJ) has made corporate culture part of its review for any company in a white-collar criminal investigation, specifically the FCPA. Today, I look at how a company can think through a process to redesign its culture.

How can you think of a different way to redesign your culture and compliance program? This is based on an article in MIT Sloan Management entitled The Four-Step Process for Redesigning Work by Lynda Gratton. Gratton believes a “fear of failure weighs heavily on many leaders tasked with managing new workplace expectations. Seeing the challenge as a process is the way forward.” Her piece provides a great way to consider the future decision to adopt hybrid or other working models.

Moreover, this fear is disrupting other areas that demand corporate attention right now and has left leaders hypersensitive to issues of retention and unsure what accommodations, if any, will attract and keep talent. They are also apprehensive about what their competitors are doing. This has a ripple effect. Because of the fear of failure, I’ve seen leaders begin to stumble on issues of inclusion, belonging, and identity. Rather than being bold and adopting an experimental mindset, they fall back to familiar operating methods and become less empathetic to what others want. When we fear failure, we retreat to the known.

I would only add that the same is true for the corporate compliance function.

In Gratton’s opinion, “Organizations need to undergo a structural overhaul, and more people than just the top leadership of an organization need to work out the task of moving forward.” Leaders who have confronted their fears and set about this task of overhaul have done it by moving through four crucial steps: understanding people, networks, and jobs; reimagining how work gets done; modeling and testing redesign ideas against core principles; and ensuring the overhaul sticks by taking action widely.”

Understand What Matters

The top fear or concern is the decision to work from home or require workers to return to the office. However, the key is “to precisely understand what matters: for example, where and how productive work takes place, what people want, and how knowledge flows.” For instance, being in the office can increase productivity for crucial tasks, particularly when it comes to individual thinking, analyzing, and writing. It turned out that being out of a busy office during lockdown was a plus for these people.

However, that is not the only equation, as “work, people, and knowledge flow differently across companies.” Gratton noted from one study participant, “Bringing ideas from all our disciplines is crucial. We have engineers, designers, planners, technical specialists, and consultants in the office. We want them to talk to each other and bounce ideas off each other.” This leadership clarity allows “an office-based way of working that would maximize highly valued cooperative behavior.”

Reimagine new ways of operating.

Understanding the focus of your compliance team can be a key driver of productivity. Still, it can also lessen “fears about pushing for an office-based way of working and enable them to be imaginative and bold.” For instance, you might create opportunities for some employees to work anywhere for three months. Once again, this might not work for all companies, but if your compliance tasks can lend themselves to this approach, it could be helpful for you to consider it going forward.

The author reported, “Unilever reimagined the employee contract—the set of promises employers make to their people.” To that end, “the conglomerate reimagined how to enable employees to work for Unilever while engaging in other activities such as starting a business, traveling, or caring for a family member. In this model, called U-Work, some employees receive a monthly retainer and earn assignment pay. Importantly, they also get pension support and access to health insurance.” This allows flexibility “between being a full-time employee and being a contractor or agency worker from a third-party organization.”

Model and test new ways of working

Any model work should be aligned with the company’s purpose or business strategy. Unfortunately, that means treating your employees like children in many top-down businesses. But if you succeeded during the pandemic (and you had to), you should be able to determine a hybrid way of working that could have a longer-term impact.

For compliance, that might mean a fuller determination of what “customer-centric means and how hybrid work would have to align with changing customer needs.” Of course, for a compliance professional, your customers could be a variety of stakeholders, such as employees, Supply Chain vendors, or other third parties. The author’s point is to “be bold and courageous in your attempt… in the spirit of being experimental.”

Act and create

An explicit concern is that new work models may become fads that are never really embedded into the company’s culture or will be discarded at the first sign of a recession or cost-cutting. While senior leadership is critical in supporting such initiatives, Gratton identified four ways to deepen engagement and support throughout an organization for such a change.

1. Managers must be engaged. A series of workshops with them helped create a managerial playbook.

2. Communication to describe how these new work models would positively impact talent attraction and retention while supporting the strategic aim of the business.

3. Managers should have open and active communication channels with their teams to reach agreements on details, such as when employees will work together in the office and when they will engage in focused work at home.

4. Managers should support each other through peer networks to support and learn from each other.

Gratton ended her piece by challenging leaders to ask themselves three questions: “Where are you now on redesigning work? Are there steps you need to take to reengage more purposefully? Are you clear about what your biggest priorities are? Your actions will create your signature work model and define the deal you are making with your employees and customers.” The same applies to a Chief Compliance Officer, the corporate compliance function, and culture.

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Compliance Tip of the Day

Compliance Tip of the Day: Redesigning 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 consider how you can think of a different way to redesign your corporate culture.

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

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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 – 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

Instagram

Facebook

YouTube

Twitter

LinkedIn

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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.

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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

Instagram

Facebook

YouTube

Twitter

LinkedIn

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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.

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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

Instagram

Facebook

YouTube

Twitter

LinkedIn