By Bill Prachar, email@example.com
Recently, I was cleaning out my basement when I came across a dozen or so bankers’ boxes full of ethics and
compliance documents that have been piling up since I got involved in the field in 1992. Among the stack were
old Codes of Conduct and compliance manuals from 100 different companies, including an old “burgundy” one
from WM. I also found Enron’s Code of Conduct — still worth something on eBay — as well as training VHS
tapes and DVDs. What a pile it was — binder after binder of policies and procedures.
All these materials got me thinking how for more than 20 years companies have been producing these ethics and
compliance documents, yet scandals still occur on a regular basis. Just this week, a person involved in the
Deepwater Horizon blowout pled guilty to destroying evidence related to the incident. What’s wrong with this
picture? Are all these training modules, communications, policies and procedures just a waste of time? Do they
really change our behavior?
The answer is not so simple. Most of the big ethical and compliance failures that get companies in trouble seldom
occur because an employee didn’t know the rules. In fact, practically never do these scandals involve some highly
technical regulatory rule that only experts can understand.
More often than not, people just make bad choices when faced with straightforward issues, and often in spite of their
training. They make poor choices to enrich themselves, their company or to get out of a jam by hiding a mistake.
So is all this stuff I’ve collected just fodder for the recycle bin? Does it serve as a reminder that 20+ years of formal
ethics and compliance programs do very little to change human nature?
My view is a little less cynical. I think good, practical, periodic training and communications do serve as effective
reminders to most employees that doing the right thing is also the best thing to do. However, there are those whose
moral compass is so susceptible to misdirection that their eyes and ears are closed to ethics and compliance
training and communications.
What they may respond to is pressure from colleagues to conform to the values of our company. At the end of the day,
people follow the model and path set by their friends and leaders. We all have a responsibility to use our moral
compass when required, and to encourage others to use theirs as well. Simply saying, “We don’t do that at WM,” can
be worth all my boxes of training materials.