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Pauline Blondet, November 24 2023

Real Skills for E&C Professionals: Creating Successful Alliances in our Organizations 🤗


Ranging from communication to leadership to problem solving to creativity and governing how we interact with teams, we don't really learn them at school or university. 

And yet, no matter how savvy we are technically, these skills can make or break our success as a human working with other humans in any organization. Even though they are harder to measure and quantify, we definitely know when they are not there and it is usually not a very pleasant experience. I would like to refer to them as "Real Skills".

In our last two blog posts, we started exploring the art of delegating:

In today’s blog post, we will explore the third and last part: how can we create effective alliances in the organization, to further promote our Ethics & Compliance agenda. 

The importance of creating strong alliances in the organizations

In a recent survey,  “lack of authority, lack of cooperation from other departments and senior management” were identified as key obstacles to improving program effectiveness (LRN 2023 Ethics & Compliance Program Effectiveness Report - this report is based on a survey of nearly 1,860 ethics and compliance professionals).

Do you feel the same?

I believe this intrinsically comes from the nature of our Ethics & Compliance functions: we coordinate the deployment of global initiatives, but we do need other teams to make these initiatives a reality, and most importantly we need every part of the business to integrate the practices, act with integrity and own it.

We cannot do it alone. Our authority does not come from our revenue generating activities, or just reporting lines. We need to earn it. And this comes from the recognition of our mission at all levels, and the acknowledgement of its critical and strategic importance for the organization.

It’s actually not about compliance, it’s about doing business with integrity

Note the change of language. Many Ethics & Compliance teams call themselves Business Integrity teams now. This change is important: it enables an easier conveying of our mission. We are not here to do paperwork or admin: we are here to help and enable doing business with integrity. This is important as it makes it much easier to convey an engaging message that resonates.

Today we will explore how to effectively ally with senior management, middle management and key gatekeeping functions in our organization.

It’s very much about personal relationships

We don’t have so much time. And yet, the building of relationships is critical in everything we do. We need to be involved personally with all other department heads at our level. And this should trickle down within our teams, too.

I need to have tight links with the Internal Control Director, and at the same time, my team members on the ground need to have tight links with the local controllers. 

We should meet regularly with all these stakeholders, with the goal to, notably:

It goes without saying and I know it is easier said than done in some organizations: we should avoid making enemies at all costs. This does not help and it makes it really hard for our teams underneath. We need to be service minded, nice, collaborative, humble and helpful, as we need help from all functions to make our program a success. We need support and allies, not barriers and enemies.

How to create and nurture our alliances, concretely

We will be focusing on three main groups:

For each group, we will prepare a high level communication & alliance plan, to make sure we get the support we need. No need to be a communication expert to do that. The idea, is to list, for each audience:

Let’s run with it.

Senior Leadership

What can we learn from Senior Leadership: we can understand their concerns, learn to speak their language, read what they read. What are their objectives and incentives to take the organization to the next level?

What we need from Senior Leadership: we need them to set the tone and lead by example.  

“The company’s top leaders – the board of directors and executives – set the tone for the rest of the company. Prosecutors should examine the extent to which senior management have clearly articulated the company’s ethical standards, conveyed and disseminated them in clear and unambiguous terms, and demonstrated rigorous adherence by example” (DOJ Evaluation of Corporate Compliance Programs (Updated March 2023)).

We need them to show the right conduct at the top, and act with integrity at all times. We need their shared commitment towards Ethics & Compliance, as well as their oversight:

“Have the board of directors and/or external auditors held executive or private sessions with the compliance and control functions? What types of information have the board of directors and senior management examined in their exercise of oversight in the area in which the misconduct occurred?” (DOJ Evaluation of Corporate Compliance Programs (Updated March 2023)).

How we get there: we need to make sure to have the right fora to speak to and exchange with Senior Leadership. If we don’t have an Ethics & Compliance Committee in place it’s time to set it up. 

You may want to write a charter that notably defines:

This is the perfect forum for continued sensitization of senior leadership, and ensuring to equip them with the right ownership and oversight and also, for collective decision making. Needless to say that this will help tremendously with the authority of the Business Integrity initiatives. 

We’re set for information, decision and oversight from Senior Leadership! Let’s also make sure that Senior Leadership shows their commitment towards the organization on a regular basis:

Every time we are launching an Ethics & Compliance initiative towards the broader organization, it is their time to shine! Let’s invite the CEO or some other Senior Leader to make a quick video, write a message, and attend the kick-off training to give a keynote.

To make this work, we need to make it easy for everyone, and all the more with senior leaders who do not have time: when we ask, we need to have prepped bullet points to enable them to easily talk about the topic and support the initiative.

Often, we see that Senior Leaders are quite engaged and sensitized, while the mid-level management displays more risk prone behavior. As part of our alliance building, it is thus critical to ensure that all levels of leadership in the organization are able to talk about Ethics & Compliance, and walk the talk on Business Integrity.

Middle Management

What can we learn from Middle Management: business teams own the responsibility to do business with integrity. Their engagement is key and yet their level of sensitivity is often way less advanced than the one of senior leadership. And yet, Middle Management is absolutely  critical in making our program a reality. We need to closely collaborate with them, understand their concerns, take their feedback into account and collaborate effectively.

What we need from Middle Management: we need them to reinforce the standards, and lead employees into the right path. We want an active community of Middle Managers, sensitized and engaged, supporting their teams in doing the right thing:

“Prosecutors should also examine how middle management, in turn, have reinforced those standards and encouraged employees to abide by them” (DOJ Evaluation of Corporate Compliance Programs (Updated March 2023)).

So, how can we effectively engage Middle Management into being our ally?

How we get there:

Knowledge and transparency 

Having Senior Leadership engaged is the first step, as people tend to care more if their bosses care. In one of my prior roles, I could personally see the huge impact of having the Head of the Africa Region being made a member of our Ethics & Compliance committee on the managers who reported to that leader! 

We want to make sure that they are effectively sensitized, they need to understand the risks, the role of the E&C initiatives as well as how they can and should contribute. They are also key to the effectiveness of reporting concerns, as most people report their concerns to their management. They need to know what we are doing in our E&C team and how this may impact them and their teams.

To nurture transparency, maybe setting up a recurring meeting in an engaging format? This could be followed by regular newsletters with an enabling package, tips and support for leaders.

Clarity on their role

Many people want to help, but do not necessarily know how to. It’s our role to enable them! How about creating a cheat sheet for our middle-managers? So that they know what they are expected to do at all times. This could for example include:

Again and again: the easier we make it for humans, the better: we need to support our middle managers with material that enables them to carry out the above. 

Recognition goes a long way

How about creating incentives to make our middle managers shine towards the broader group? There are many ways to reward and recognize, from thanking people, to mentioning their name  to their boss, to the E&C Committee, the CEO, and so on. 

Maybe use the regular collective meetings to include a best practice sharing session? A manager to share what they have done to further integrity in their team, or have they have handled a complex ethical dilemma. Being able to shine creates a positive dynamic and a virtuous circle! It makes more people want to shine.

Going further on recognition, sky and your creativity is the limit: create awards, shout outs, and whatever gives you and the people involved joy!

And of course, we want to work with HR to ensure all managers have some business integrity objectives and that rewards, promotions and incentives are assessed in the light of doing business with integrity.

Collect feedback genuinely

Humans cannot be truly engaged in something they cannot impact. Try to listen actively and get their feedback. You’d be surprised by how many amazing ideas engaged teams can bring to the table. At the end of the day, Business Integrity is everyone’s responsibility and we want to create ownership. A great way to do so is to ask for feedback: we need to know what we need to adjust to be more effective!

Now that we have explored how to build strong alliances with Senior Leadership and Middle Management, I would like to focus on Gatekeeping functions.

Gatekeeping functions

Last but not least, let’s talk about Gatekeeping functions. They are our allies by nature. From HR to Internal Control, from Audit to Accounting to Legal, their role is key to making our initiatives a reality.

What can we learn from Gatekeeping functions: we learn that we cannot do it alone. These functions are critical in making our program a reality. We have to closely collaborate with them, understand their concerns, take their feedback into account, and we must make it work.

What we need from Gatekeeping functions: we typically need them to help us roll out our initiatives. No policy or training can become a success without the help of HR. We do need the internal control referential to include E&C Controls, and for that we need the leader of this function to agree to include them. We need to work with the accounting team on creating effective accounting controls. We need legal to include our Ethics & Compliance clauses in every contract and make sure our Supplier Code of Conduct is appendiced effectively. The list is long!

How we get there:

We need to work extremely closely with all gatekeeping functions to build a habit and culture of cross-functional collaboration. This starts at the top. We must not only endorse but actively demonstrate the importance of collaboration in achieving our goals. We want to align with the leaders of these functions closely, in order to encourage open communication and shared responsibility. Below a few ideas to nurture this culture:

Conclusion

By creating successful alliances at all levels of our organisation, we are working to create and nurture a culture of business integrity. It takes time, it takes relationships building, it takes energy. It requires putting our egos aside to truly collaborate on doing what’s best for the company. But what a reward when it works and you can feel that friends and advocates are everywhere, taking your E&C program to life, and to the next level.

Follow Upright Solutions on Linkedin for more inspiration to lead your E&C Team and initiatives.

Love from Copenhagen đź’ś


/risk-assessments

Written by

Pauline Blondet

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