“Over the past few months, senior leaders at both the Department of Justice (DOJ), and Securities and Exchange Commission (SEC), have given speeches discussing the need for appropriate corporate culture around compliance. So, this brings up our first question for our next five-part blogpost series, what is corporate culture?
My colleague Eric Feldman believes “culture is everything” for an organization; culture is the foundational internal control, without which all your other controls are likely to be ineffective.
This means corporate culture is the way things really are in an organization and the way things really work. While corporate culture can be reflective of the core values of a company, this usually only occurs only if the company operationalizes those values throughout the organization.”
“A company does not have an ethical culture unless top management commits to it. Employees not only listen to what senior leadership says but they watch how they act.
Employees look for signals about what really counts in an organization. But you must then move down to implementation of this goal. Employees want to know if senior leadership is committed to the company’s core values.”
“Let’s consider that there are multiple levels and roles for those within and outside of the corporate compliance function within an organization; they include the CCO, a compliance practitioner and the compliance function itself. What is the role of the corporate compliance function itself in strengthening the ethical culture of an organization?
It all begins with the response to a simple question: “Who is responsible for culture in an organization?” Within the C-Suite level, you might get a response that the CEO, head of HR or perhaps the general counsel is responsible.
These disparate responses underscore the uncertainty of who really bears the responsibility for culture, although intuitively, most employees understand that everyone is responsible for culture. The point is, you must look at the operations of a company through the prism of whether or not it is consistent with the company’s core values.”
“How can a company assess its own culture? First, we should consider whether the company is able to perform a self-assessment of its own culture or whether it should engage a truly independent professional to do the assessment. Both approaches are valid, but each has a different focus.”
“Companies leave a trail of breadcrumbs when they design and implement practices that lead to an ethical culture. We need a framework for such an assessment, and it makes sense to start with the program itself. This involves a thorough review of the organization’s compliance program; what does it look like and does it meet the foundational tenants?”