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FCPA Compliance Report

FCPA Compliance Report – The 2024 ECCP on Data-Driven Culture and Engagement

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this edition, Tom Fox visits with Sam Silverstein on how compliance professionals should view the new DOJ mandate on using data to assess, manage, and improve corporate culture through data-driven compliance. The Culture Audit sponsors this podcast.

In this comprehensive discussion, Tom Fox and Sam Silverstein delve into the 2024 Update to the Evaluation of Corporate Compliance Programs (ECCP) by the DOJ. Released in September, this latest update emphasizes the importance of data analytics, culture, engagement, and trust in compliance programs. With a detailed breakdown of over 250 questions posed by the ECCP, Tom and Sam provide valuable insights on how companies can benchmark their compliance programs and prepare for potential investigations. They highlight the role of a culture audit in addressing the DOJ’s requirements, offering a detailed look into how organizations can measure and improve their compliance culture. This webinar educates compliance professionals on the latest DOJ expectations and provides practical tools and methodologies to enhance corporate compliance efforts.

Highlights in this episode:

  • Importance of Culture and Data Analytics
  • Leveraging Data for Compliance
  • Measuring and Improving Culture
  • Data-Driven Culture of Compliance
  • Understanding and Utilizing Culture Audit Data
  • Forward Steps for a Stronger Culture

Resources:

Culture Audit

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Sam Silverstein and the Accountability Institute

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Tom Fox

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Culture Crafters

Culture Crafters – Turning Around a Toxic Culture: Part 5 – Ongoing Monitoring and Continuous Improvement of Culture

Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other myriad of corporate scandals where culture failed and created a toxic culture. The question for any organization in such a situation is how to transform its culture.

In this special five-part podcast series, Sam Silverstein, the most trusted voice in America on accountability, and Tom Fox, the Voice of Compliance, look at the ways a company in the depths of such a situation can plan out and take concrete steps to turn around and rebuild its culture. In this concluding Part 5, we explore the dynamism of culture and why ongoing monitoring and continuous improvement are so critical for a true culture transformation.

Leaders must set a clear vision for a positive culture, emphasizing values such as excellence, safety, and community involvement, and stress the importance of proactive actions to foster a culture of excellence. However, even after assessing a culture, the culture transformation strategy, and the plan’s implementation, the culture transformation must be nurtured through ongoing monitoring and continuous improvement. Leaders must make culture a primary objective, consistently demonstrating core values while advocating for continuous culture monitoring and improvement. Both agree that cultivating a solid culture improves the organization’s bottom line, enhances the quality of products, and contributes to the betterment of communities.

Key Highlights:

  • Continuous Monitoring of Organizational Culture
  • Driving Cultural Change in Mergers Successfully
  • Culture is Dynamic

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

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Culture Crafters

Culture Crafters – Turning Around a Toxic Culture: Part 4 – Design and Implementation of a Culture Transformation Strategy

Boeing has recently seen one of the most public meltdowns over corporate culture. In 2024 alone, there have been multiple incidents, allegations, and reports about the company in the public arena. The company is under investigation by numerous governmental agencies. Several news organizations have reported a ‘toxic’ culture at the company, and there are ripples throughout the worldwide aviation industry. In such a situation, the question for any organization is how it thinks about turning around its culture. In this special five-part podcast series, Sam Silverstein, the most trusted voice in America on accountability, and Tom Fox, the Voice of Compliance, look at the ways a company in the depths of such a situation can plan out and take concrete steps to turn around and rebuild its culture. In Part 4, we consider using the results from The Culture Audit™ to design and implement the transformation strategy.

The pivotal role of leadership in constructing and maintaining organizational culture is an intriguing and vital topic. Tom Fox, a strong advocate of taking action to communicate values within an organization, asserts that leaders who genuinely care about their employees and demonstrate this through their actions inspire loyalty and dedication, thereby creating a solid foundation for a positive workplace culture. Similarly, Sam Silverstein emphasizes the role of leadership in fostering a culture that values consistency, trust, and mutual respect. Silverstein posits that leaders who show they are there for their team members in times of need and consistently support them create a positive workplace culture where employees are willing to go the extra mile. Both experts stress that actions speak louder than words and that authentic leadership involves embodying the values of honesty, integrity, and care for others.

Key Highlights:

  • Values-Driven Assessment of Organizational Culture
  • Upholding Values Through Decisive Organizational Actions
  • Cultivating Organizational Culture through Intentional Leadership

Resources:

 Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

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Culture Crafters

Culture Crafters – Turning Around a Toxic Culture: Part 3 – Assessing Culture

Boeing has recently seen one of the most public meltdowns over corporate culture. In 2024 alone, there have been multiple incidents, allegations, and reports about the company in the public arena. The company is under investigation by numerous governmental agencies. Several news organizations have reported a ‘toxic’ culture at the company, and there are ripples throughout the worldwide aviation industry. In such a situation, the question for any organization is how it thinks about turning around its culture. In this special five-part podcast series, Sam Silverstein, the most trusted voice in America on accountability, and Tom Fox, the Voice of Compliance, look at the ways a company in the depths of such a situation can plan out and take concrete steps to turn around and rebuild its culture. Part 3 is assessing your culture to develop a transformation strategy through The Culture Audit™.

The Culture Audit™ is a powerful tool for assessing an organization’s culture, providing a comprehensive analysis of its values, employee engagement, and accountability. It serves as a diagnostic tool, pinpointing strengths, weaknesses, and areas for improvement. Think of it as a health check-up for your organization, revealing insights into aspects of your workplace culture that may not be immediately apparent. The value of cultural assessments extends beyond regulatory compliance; they empower leaders to foster an environment where ethical decisions are second nature.

Silverstein emphasizes the essence of an action plan based on audit results to bring about desired improvements. Both Fox and Silverstein agree on the value of an external perspective in auditing and enhancing organizational culture. From The Culture Audit™, you can move to strategy design and implementation.

Key Highlights:

  • Culture Evaluation Through Comprehensive Cultural Audit
  • Truthful Insights through Anonymous Culture Assessment
  • Using Data to Design a Culture Transformation Strategy

Resources:

 Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

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Blog

Transforming Culture: Part 3 – Assessing Change Through the Culture Audit™

Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other myriad of corporate scandals where culture failed and created a toxic culture. The question for any organization in such a situation is how to transform its culture. Currently running on the Culture Crafters podcast on the Compliance Podcast Network is a 5–part of podcast series with myself and Sam Silverstein, the most trusted voice in America on accountability. (The Culture Audit™ is the sponsor of this blog post series.)

Over this companion, 5-part blog post series, we look at how a company in the depths of such a toxic culture can begin to make a culture comeback by planning and taking concrete steps to turn around and rebuild its culture. In Part 3, we consider assessing change through The Culture Audit™ as a starting point for culture transformation.

The Culture Audit™ plays a pivotal role in culture transformation. It serves as a structured framework for assessing key cultural aspects, providing a comprehensive analysis of strengths and areas needing improvement. By leveraging this assessment tool, organizations can gain valuable insights into their cultural landscape, paving the way for informed decision-making and targeted interventions to drive positive change. The Culture Audit™ is not just about knowing the existing culture, but about providing actionable insights and an action plan for organizations to implement changes and enhance their culture effectively. Its true transformative potential lies in its ability to catalyze meaningful cultural shifts by pinpointing areas of alignment and discord within an organization.

The Culture Audit™ provides organizations with a clear roadmap for culture transformation. The emphasis on anonymity within the audit process lets employees express their perceptions candidly, fostering a culture of openness and transparency. By providing a platform where individuals can share their feedback without fear of retribution, organizations can obtain honest and valuable insights to understand the actual state of their culture.

The Culture Audit™ stands out from traditional assessment strategies due to its unique features. It offers ease, speed, accuracy, and anonymity, making it a cost-effective and efficient tool for organizations striving to enhance their culture. Its ability to support multiple languages ensures accurate and in-depth insights from diverse workforce populations, further setting it apart from other tools.

The Culture Audit™ measures various aspects of a company’s culture, including compliance practices, hiring processes, and employee engagement. It generates a comprehensive report highlighting gaps and providing actionable improvement steps. The tool mainly benefits 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 tool provides a detailed report that can be shared to demonstrate the company’s commitment to assessing and improving its culture. The Culture Audit™ goes beyond basic measures of engagement and assesses accountability and decision-making processes, providing a comprehensive view of an organization’s culture. The raw data collected during The Culture Audit™ is also retained for future reference, allowing organizations to track their progress over time.

The Culture Audit™ brings significant benefits to organizations. It not only identifies areas for improvement but also provides actionable insights. The audit report includes a detailed action plan that guides organizations on specific areas to focus on and steps to take for improvement. As Silverstein emphasized, by continuously reinforcing positive aspects of their culture, organizations can prevent a decline over time. This continuous improvement approach is crucial for all companies, whether they are underperforming or reinforcing what they are already good at.

In conclusion, The Culture Audit™ 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 regulators’ increasing focus on corporate culture, 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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Blog

Transforming Culture: Part 2 – The Role of Leadership

Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other myriad of corporate scandals where culture failed and created a toxic culture. The question for any organization in such a situation is how to transform its culture. Currently running on the Culture Crafters podcast on the Compliance Podcast Network is a 5–part of podcast series with myself and Sam Silverstein, the most trusted voice in America on accountability. (The Culture Audit™ is the sponsor of this blog post series.)

In this companion, 5-part blog post series, we look at how a company in the depths of such a toxic culture can begin to make a comeback by planning and taking concrete steps to turn around and rebuild its culture. In Part 2, we consider the role of leadership in any cultural transformation.

Exploring the pivotal role of senior leadership in driving cultural change underscores the top-down approach necessary for successful transformation. In organizational culture, the influence and accountability of senior management and the Board of directors cannot be overstated. Leaders at the helm of an organization must demonstrate unwavering commitment to shaping a positive culture by embodying the values and behaviors they wish to instill throughout the company.

But what are the implications of leadership beliefs and actions on cultural transformation? Leaders must consistently demonstrate their commitment to ethics, quality, and employee well-being. Leaders serve as the ultimate culture architects. Senior leaders set the tone for the entire organization through their decisions, communication, and actions, influencing every aspect of the workplace culture and employee behavior. This underscores the direct correlation between leadership effectiveness and the successful transformation of a toxic culture into one that thrives on trust and accountability.

Sam Silverstein encapsulated the essence of the discussion: “Well, everything rises and falls on leadership.” This highlights the significant impact that leadership has on organizational culture and success. This simple yet profound statement encapsulates how influential leaders set the tone for organizational culture. Whether steering the ship toward a new direction or reinforcing existing values, senior leadership is the guiding force that shapes the managerial ethos.

The Board’s strategic imperative is upholding and championing organizational culture and its transformation. A Board must protect and defend the culture as the first point in its strategic plan. A committed board can set the tone for a culture transformation that attracts and retains top talent while fostering sustained success.

Aligning corporate beliefs with action is critical as well.  There is a stark contrast between leaders who merely pay lip service to values like quality and ethics and those who actively embody and champion these principles. True leadership requires a deep commitment to values that resonate throughout the organization. A CEO must engage in trust-building and fostering accountability within an organization. This includes demonstrating an unwavering commitment to their people, earning their trust, and enabling them to perform at their best.

One way to do so is the cascade effect of organizational cultural change. Leaders at every level must uphold and prioritize a company’s defined values. By holding everyone accountable and ensuring alignment with the organization’s cultural ethos, leaders can drive meaningful change from the top down and engender trust. Trust catalyzes organizational success. When leaders prioritize building trust with their teams, they empower individuals to move forward confidently and speedily, ultimately driving higher productivity and engagement.

Key takeaways for leaders include the well-worn maxim that Actions Speak Louder Than Words. This means they must not simply state their values but actively demonstrate them through their actions. Leaders must visibly display actions and make decisions that connect to and support them. This authenticity and consistency in behavior are essential in fostering a culture of trust and accountability.

CEOs are accountable for fostering cultural change by prioritizing their people and standing up for values such as quality and ethics. The accountability is to his people or her people and for their people. This accountability involves being accessible, listening to employees, and taking decisive action to uphold the desired culture.

In conclusion, effective cultural transformation requires strong leadership commitment, visible actions aligned with values, and a cascading effect of cultural priorities from the top down. Organizations can create a positive workplace environment that drives success and employee satisfaction by prioritizing ethics, valuing people, and fostering a culture of trust. As Sam Silverstein aptly puts it, “When your people fully trust you, they can go forward at a much faster speed.”

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Culture Crafters

Culture Crafters – Turning Around a Toxic Culture: Part 1 – The Problem

Boeing has recently seen one of the most public meltdowns over corporate culture. In 2024 alone, there have been multiple incidents, allegations, and reports about the company in the public arena. The company is under investigation by numerous governmental agencies. Several news organizations have reported a ‘toxic’ culture at the company, and there are ripples throughout the worldwide aviation industry. In such a situation, the question for any organization is how it thinks about turning around its culture. In this special five-part podcast series, Sam Silverstein, the most trusted voice in America on accountability, and Tom Fox, the Voice of Compliance, look at the ways a company in the depths of such a situation can plan out and take concrete steps to turn around and rebuild its culture. In Part 1, we consider the steps that led Boeing to the current state of its corporate culture.

A culture does not go toxic overnight. There are always multiple steps, roads taken (or perhaps not taken), and sometimes years for the toxicity to manifest itself. The cultural problems of Boeing can be traced back to its 1997 merger with McDonnell Douglas, which has since manifested in significant safety and quality issues. This issue highlights the importance of prioritizing quality over stock performance, a lesson to be learned for the future of the commercial airline industry. The root of Boeing’s problems lies in this shift in culture post-merger, from a quality-driven ethos to a profit-centered one, leading to a compromising situation for safety and quality. The company needs a cultural transformation that values quality, safety, and employee feedback for an improved company reputation. Silverstein highlights that the company’s cultural problem stems from a shift towards short-term financial gains after the merger. Drawing on his expertise in accountability, Silverstein underlines the importance of a culture that values quality, safety, and open communication, which is vital for attracting top talent, enhancing productivity, and, ultimately, maximizing profitability.

Key Highlights:

  • Shift in Boeing’s Prioritization Towards Stock Performance
  • Impact of Culture on Mergers and Acquisitions
  • Workplace Culture’s Influence on Business Outcomes

Resources:

 Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

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Blog

Transforming Culture: Part 1 – From Merger to Culture Toxicity

Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other myriad of corporate scandals where culture failed and created a toxic culture. The question for any organization in such a situation is how to transform its culture. Currently running on the Culture Crafters podcast on the Compliance Podcast Network is a 5–part of podcast series with myself and Sam Silverstein, the most trusted voice in America on accountability.

Over this companion, 5-part blog post series, we look at how a company in the depths of such a toxic culture can begin to make a culture comeback by planning and taking concrete steps to turn around and rebuild its culture. In this concluding Part 5, we explore the dynamism of culture, assessing culture through The Culture Audit™ (the sponsor of this blog post series), putting together a plan to remediate your culture and implementing that plan, and conclude with why ongoing monitoring and continuous improvement are so critical for a true culture transformation. In Part 1, we consider the steps that led Boeing to the current state of its corporate culture.

Boeing’s cultural miasma led to the 737 MAX crisis, which has tarnished the company’s reputation and raised doubts about its future in the commercial airline industry. Yet the company’s slide into cultural toxicity began long before the 737 MAX disasters. From these pre-pandemic disasters, the company now finds itself in one of the worst places in recent memory for a company’s reputation.

The slide began with the merger with McDonnell Douglas back in 1996. This led to a shift in leadership, which transformed the company’s culture by prioritizing stock performance over quality. This emphasizes the importance of cultural due diligence in mergers and acquisitions, with the need to evaluate existing cultures, plan post-merger integration, and uphold a robust culture within the acquiring firm. The significance of workplace culture was highlighted as a pivotal factor influencing stakeholders, from employees to customers, impacting talent retention, productivity, and overall profitability.

The culture that permeates an organization’s operations plays a pivotal role in determining its outcomes. A toxic culture characterized by shortsightedness, a profit-over-quality mentality, and a lack of ethical standards can have catastrophic consequences for the organization as a whole. Such cultures often prioritize immediate gains at the expense of long-term sustainability, leading to compromised quality, ethical dilemmas, and damaged stakeholder relationships.

The merger with McDonnell Douglas in 1997 marked a turning point for Boeing. A shift towards a culture focused on stock performance and short-term gains took precedence over a culture of engineering excellence. This shift strayed from Boeing’s legacy of quality and engineering excellence, resulting in significant setbacks like the 737 MAX crisis. The Boeing situation underscores the importance of upholding a culture that values integrity, quality, and long-term success to avoid such catastrophic outcomes.

 Mergers and acquisitions are complex processes that extend beyond financial considerations to encompass cultural integration. The compatibility of organizational cultures is a critical factor that can significantly impact the success or failure of such strategic decisions. To mitigate risks and facilitate a smooth transition, assessing cultural alignment, creating a clear roadmap for integration, and ensuring a strong, cohesive culture in the new entity are essential steps that leaders must prioritize during mergers and acquisitions.

In the context of mergers and acquisitions, culture synergy is critical, and indeed, the Boeing-McDonnell Douglas merger is a cautionary tale. The takeover of Boeing by McDonnell Douglas’s leadership brought about a cultural shift that veered away from Boeing’s core values, leading to subsequent challenges. Organizations embarking on such endeavors must pay close attention to cultural compatibility and actively work towards fostering a unified culture built on shared values and objectives. All of this underscores the critical role of culture in shaping the success of strategic business decisions like mergers and acquisitions.

The bottom line is that the best cultures are always the ones where senior leadership at the top always asks, how can we improve this culture?” This emphasizes the need for organizations to continually prioritize ongoing efforts to enhance their workplace culture. Action follows belief. This underscores the notion that an organization’s outcomes are rooted in its beliefs and values. Companies like Boeing can drive positive actions and results by fostering a culture that prioritizes quality and safety.

When you create a fantastic workplace culture, it goes home with your people. It impacts their spouses. It affects other businesses in the community. This serves as a poignant reminder of the far-reaching influence of workplace culture on individuals and broader societal interactions.

With this unique narrative, Boeing demonstrates the profound impact of leadership on culture and the overall organizational environment. Yet this sets the stage for exploring strategies to transform toxic cultures into thriving, ethical ones for CEOs and organizational leaders seeking actionable insights. I hope you will join us for the rest of the blog posts this week, in which we show how a company can transform its culture.

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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

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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

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Twitter

LinkedIn