Empowering ethics: Unleashing compliance program success through psychological safety | Society of Corporate Compliance and Ethics (SCCE)
[author: Jennifer Mason*]
Ethikos 38 no. 3 (July 2024)
Since Harvard Business School’s Amy Edmondson applied the term “psychological safety” to work teams in 1999, the concept has evolved considerably as employers have become increasingly focused on supporting mental health, engaging in more agile ways of working, and promoting inclusivity. In today’s organization, psychological safety has shifted from a notion that is merely “nice to have” to an essential, as it improves team members’ professional lives, promotes their personal well-being, drives innovation, establishes meaningful relationships, builds trust, and just makes good business sense. As organizations are recognizing the value through improved team member engagement, business innovation, and profitability, we’d be remiss—as compliance professionals—if we didn’t also recognize the undeniable impact it has on the effectiveness of the programs we strive to build and maintain.
What is ‘psychological safety’?
Psychological safety is a concept that refers to an individual’s perception of the work environment as a safe space for taking interpersonal risks, sharing ideas, asking questions, and expressing concerns without the fear of negative consequences.[1] In psychologically safe environments, team members feel comfortable being themselves, contributing their opinions, and engaging in open and honest discussions, which ultimately fosters collaboration, innovation, and well-being.
Why the evolution
When Edmondson first presented the notion of psychological safety, the emphasis was on creating a team environment conducive to learning and improvement. Her research underscored that psychological safety fosters open communication and risk-taking, positioning teams to think differently and learn from their failures.[2] As teams with psychological safety thrived and organizations reaped the benefits, the concept expanded beyond individual teams to shape overall organizational culture.
Leaders now appreciate that cultivating an environment where team members can freely express concerns and ideas without fear enhances trust, collaboration, and adaptability. Even before the pandemic (but increasingly more so because of it), the more progressive approach to employee mental health has further driven the evolution of psychological safety in the workplace.[3] Team members have faced having to contend with unprecedented challenges at home, working long hours, and making tough decisions between right and wrong and sometimes even between life and death when they report to work each day. As a result, employers are increasingly focused on creating an environment where team members can openly discuss stress, mental health challenges, and work-related pressures without judgment or repercussions. Such an environment contributes to individual and organizational well-being and cultivates trust among leaders and teams.
In this post-pandemic world, the workplace is now more diverse and dynamic than before.[4] You have team members who never leave their homes or their computers and may rarely physically interact with their colleagues or leaders. You have team members balancing the challenges of a hybrid role where there is sometimes frequent travel, limited work time in front of their computers, and family commitments on top of it all. And then you have those who have had to consistently report to the hospital, practice, or office but may potentially harbor some resentment for their colleagues who had more flexibility during the pandemic and who may continue to do so now. These team dynamics, coupled with the increasingly more common need for cross-functional collaboration among colleagues, further drive the importance of fostering an environment where team members consistently feel comfortable sharing ideas and raising concerns regardless of how or where they work.
‘Move fast and break things’
While those of us in compliance may not quite be ready to fully adopt Mark Zuckerberg’s motto, “Move fast and break things,” many of us are in positions to ensure the programs we are developing and leading better align with and promote our organizations’ values and strategies. With the unprecedented challenges facing many companies in this post-pandemic world, these strategies may now involve “breaking things” or looking to do things in drastically new and different ways. The dynamics of business these days—staffing crises, rising costs, supply chain disruptions, financial hardships, economic uncertainty, digital transformation—are driving organizations to be even more focused on innovation and differentiation, requiring that our business leaders think more like Zuckerberg than many of us traditionally risk-averse professionals would prefer. This is where psychological safety comes into play.
When we cultivate an environment where people are comfortable both bringing up new ideas and raising concerns, the environment not only promotes speaking up without fear of rejection or retaliation, but it also promotes including compliance professionals in solution development instead of just cleaning up if and when things go awry. You fundamentally shift from being the person they call when something breaks to the person who helps develop ideas to improve the business overall, potentially avoiding the breaking altogether.
Fostering fearlessness
Whether you are a compliance leader in a complex organization, an individual contributor in a small start-up, or a rising compliance superstar, the following are a number of ways you can help create the culture of psychological safety that results in compliance getting a seat at the table (and, more importantly, having influence) when innovative ideas are being discussed and fostering a culture where speaking up is celebrated, not retaliated.
Set the tone and lead by example
Demonstrate open communication, active listening, and a willingness to admit mistakes and take steps to correct them. Listen with the intent to understand and not necessarily to immediately respond. When organizational leaders and team members see that you value feedback and handle concerns constructively—and that you keep it positive and nonjudgmental—they trust you and are more likely to engage with you.[5]
Offer anonymity
Sometimes, regardless of how much you and your organization’s other leaders do to help people feel safe, team members may still not be comfortable raising concerns (or new ideas). Recognizing this, be sure your organization has processes in place that allow team members to raise concerns (or bring up innovative ideas) without revealing their identities. Pro tip: Tracking the frequency with the anonymous option can also be a great metric for gauging the efficacy of psychological safety in your organization.
Investigate with integrity and transparency
When concerns are raised, ensure your investigations thoroughly review all facets of the concerns reported and, as much as possible, be sure to keep reporters informed of the process and outcomes. This shows team members that their concerns are taken seriously and addressed appropriately.
Adopt a non-punitive approach
Avoid the “gotcha” mentality. Stress to team members that the organization values learning from mistakes and strives to prevent future missteps rather than placing blame. This is not to say that there should not be consequences for misconduct. The U.S. Department of Justice’s Evaluation of Corporate Compliance Programs calls on organizations to “identify, investigate, discipline, and remediate violations of law, regulation, or policy.”[6] Be thoughtful about how you address concerns, ensure that egregious behavior is addressed appropriately and consistently. Pro tip: Tracking and trending your disciplinary actions and other remediation efforts is another great metric to show program effectiveness and alignment with the department’s recent guidance.
Encourage questions
Promote a culture where team members feel comfortable asking questions about policies, procedures, and compliance matters. Encourage curiosity and the pursuit of understanding. Pro tip: I actually include “intellectually curious” as a characteristic on many of the job descriptions for my team. It’s even better if your organization’s values or guiding behaviors stress this too.
Recognize and reward
Whether it’s a simple thank-you message or a more formal program, come up with ways to recognize and reward team members who proactively raise concerns or propose process improvements. The Evaluation of Corporate Compliance Programs recommends that organizations provide “positive incentives, such as promotions, rewards, and bonuses for improving and developing a compliance program or demonstrating ethical leadership.” If your organization already has a recognition program, consider ways to incorporate promoting ethics and compliance and raising compliance concerns into it. Also, consider working with your executive leadership, compensation team, and board to ensure you have a means of incorporating recognition opportunities into your organization’s incentive plans.
Secure senior leadership support
You alone cannot single-handedly change the culture throughout your organization. Work with your senior leadership team to endorse and model psychological behavior. Meet them where they are, recognizing that this may be a novel concept to many. Identifying the business benefits of such a culture—innovation, employee engagement and retention, and more—will make this an easier sell than you might think.
Gauge effectiveness
Once you have your strategy in motion, take some steps to gauge team members’ perceptions of psychological safety when reporting concerns. This can be done through quick pulse checks or a more involved culture of compliance surveys. Make sure you ask open-ended questions to get candid input. Share these results with your organization’s leaders and identify actionable steps that you can take together to continue fostering a psychologically safe environment.
Become the department of how
While it may be easier to always just say no, it will quickly result in you no longer being invited to the party. When you are invited to discuss innovation, that’s a win in and of itself. Take time to understand the drivers behind what stakeholders want to do and help come up with a solution—one compliant with policies and the law, of course.
Seek to continuously improve
Continuously assess and refine your organization’s policies and processes based on feedback and lessons learned and communicate how to do so. Demonstrating a commitment to improvement reinforces psychological safety. For larger-scale compliance issues, we often hold a cross-functional after-action meeting where we candidly discuss what went wrong, how we could have prevented it, and what we need to change to keep it from happening again. It’s an incredibly eye-opening and empowering exercise that positions team members in all parts of the organization to help make our organization better.
Share the wealth
While the notion of psychological safety is growing in business, not everyone is up to speed on it. Consider focusing on how to promote psychological safety in the workplace in leadership training and communications. Where possible, partner with your human resources and organizational development teams to develop tool kits to help leaders foster the culture. Author and organizational anthropologist Timothy Clark offers a very pragmatic framework to share with leaders, offering just seven questions on how to assess personal impact on a team’s psychological safety (Figure 1).[7] Perhaps start by sharing this. At the employee level, compliance professionals can focus on making sure team members understand their rights and protections when reporting concerns. Stress that raising concerns and reporting misconduct is an act of responsibility rather than disloyalty.
Conclusion
You cannot create a culture of psychological safety in your organization alone, and it will not happen overnight. Promoting this type of culture will require ongoing focus, effort, and commitment amongst your leadership team. However, as compliance professionals, we are in positions to be catalysts in this movement. By building a compliance program that promotes transparency, integrity, and trust, you can empower team members and ethics throughout your organization.
Takeaways
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Cultivating psychological safety in the workplace can foster innovation and profitability but also trust, which promotes the speak-up culture that compliance professionals continuously aspire to attain.
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Compliance professionals can focus on the approachability of their function to help set the tone for psychological safety within their organization.
*Jennifer Mason is the Vice President of Enterprise Compliance & Ethics at McKesson in Dallas, Texas, USA.
1 Amy C. Edmondson, “Psychological Safety and Learning Behavior in Work Teams,” Administrative Science Quarterly 44, no. 2 (June 1999): 350–383,
2 Amy C. Edmondson, The Fearless Organization: Creating Psychological Safety in the Workplace for Learning, Innovation, and Growth (Hoboken: Wiley, 2018).
3 World Health Organization, “WHO Director-General’s opening remarks at the Mental Health at Work panel, World Economic Forum,” speech, January 18, 2023,
4 Alina Clark, “5 Common Problems Plaguing Remote Workers And What To Do About Them,” Forbes Business Journal, July 22, 2021,
5 Kim Scott, Radical Candor: Be a Kick-Ass Boss Without Losing Your Humanity (New York: St. Martin’s Press, 2017).
6 U.S. Department of Justice, Criminal Division, Evaluation of Corporate Compliance Programs, Updated March 2023,
7 Timothy R. Clark, The 4 Stages of Psychological Safety: Defining the Path to Inclusion and Innovation (Oakland, CA: Berret-Koehler Publishers, 2020).
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