November 8, 2024

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How to sell ethics and compliance to your organization | Society of Corporate Compliance and Ethics (SCCE)

How to sell ethics and compliance to your organization | Society of Corporate Compliance and Ethics (SCCE)

[authors: Pauline Blondet and Carolina Silva*]

Ethikos (October-December 2024)

As ethics and compliance professionals, we work hard to create robust programs. But is this enough in a trade where we seek everyone’s adherence to our values? How do we communicate about what we do? Are we visible to the broader organization? How do we leverage other functions—particularly leaders—to trickle down our message? In this article, we will provide insight and practical tips on how to effectively invest in our communication and thus sell our critical mission to the broader organization to have a lasting cultural impact.

Getting your product, brand, and message right

Product

The first thing to do will be to identify what you are selling. Are you selling compliance, are you selling ethics, are you selling business integrity? There is no right or wrong answer to this, but it is important to identify what works for you and your organization. To help answer this question, we recommend focusing on outcomes rather than processes, as your product needs to bring value to the table. Once defined, make sure to have this product name consistently used, from your team’s name (e.g., “Business Integrity Team” or “Ethics Team”) to your newsletters, slides, communication and engagement materials, or any other relevant materials.

Brand

A brand can be defined as “a public image, reputation, or identity conceived of as something to be marketed or promoted.”[1] Our brand needs to enable internal colleagues to distinguish us from other internal teams (competition, if you will). This is an invitation to have an identifiable logo or color identity that will make you easily recognizable. The idea is to be seen and identified. Depending on the organization, this may be easier or harder. We advise you to work with your internal communications department to see what can be done within the framework of the company guidelines. Even in the strictest of setups, something as simple as swapping around the agreed colors may be feasible and make your communication stand out.

Message

The most significant point of a selling strategy is having an effective message; it should resonate with the audience and, ideally, make them adhere to it and embrace the collective mission of doing business with integrity. Your core message should be short and engaging and focus on the value you bring. It’s basically a sales pitch.

To craft an effective pitch, it’s essential to take a step back and dive into what drives behavior in human action. Simon Sinek, in his 2009 TED Talk on “How great leaders inspire action,” has analyzed what makes great companies so successful: it turns out that they all communicate in the same way.[2] They focus on why they exist (their purpose) rather than listing what they do or even explaining how they do it. According to Sinek, this way of communicating works so well because it is grounded in biology:

None of what I’m telling you is my opinion. It’s all grounded in the tenets of biology. Not psychology, biology. If you look at a cross-section of the human brain, from the top down, the human brain is actually broken into three major components that correlate perfectly with the golden circle. Our newest brain, our Homo sapien brain, our neocortex, corresponds with the ‘what’ level. The neocortex is responsible for all of our rational and analytical thought and language. The middle two sections make up our limbic brains, and our limbic brains are responsible for all of our feelings, like trust and loyalty. It’s also responsible for all human behavior, all decision-making, and it has no capacity for language.

To drive human behavior, it’s vital to speak the language of purpose and express one’s “why.” What we do and how we do it are of course important, but they will likely not trigger decision-making, even though they may help post-rationalize our behavior.

This means your message should focus on your why, your purpose, your mission. A simple yet effective way to do so could be to ask yourselves, “Why are we here?” Try to answer and then ask why again. Repeat the exercise four or five times until you get to the essence of things. For ethics and compliance teams, this may end within the lines of enabling teams to do business with integrity, protecting the company, and so on.

Pitch

Once you are clear on why you exist, we propose packaging this in a simple yet effective pitch, following a methodology that was developed by Oren Klaff in his inspiring book Pitch Anything.[3] It is composed of the following steps:

Step 1: Introduce yourself (10 seconds)

This needs to be brief: your name, your team, maybe mentioning something colleagues have seen already (your integrity hotline, for example): “Nice to meet you. I’m Pauline from the Business Integrity Team. Maybe you’ve heard of our integrity week?”

Step 2: Present your “why” (10 seconds)

This is a brief statement that summarizes the purpose you have identified. This could be, for example: “The Business Integrity Team is here to protect the company, its people, and its reputation.”

Step 3: Explain what we face (30 seconds)

This point needs to be dynamic and slightly worrying. Why would one adopt the solution you propose if one is not facing adverse forces and a challenging environment? In the field of ethics and compliance, this step is pretty easy, given the regulations, their aggressive enforcement, as well the increased scrutiny of shareholders and stakeholders. You could use something like this: “As a global organization, we face regulations that require us to take proactive steps to act with integrity. They are enforced aggressively and, when they hit, may lead to fines in the millions (sometimes billions) of dollars, jail time for people involved, loss of business, and a destroyed reputation.”

Step 4: Propose the solution and add a call to action (20 seconds)

Faced with such a harsh environment, what you sell is the solution. This is also where you want to bring the point home and call for action. This last point should describe what you do and why you need everyone’s support. This could be something along these lines: “We create and deploy ethics programs to ensure this does not happen to us. We work hard to protect the company, its employees, its reputation, and secure the future of business. Ultimately, if we do this well, we also contribute to making the world a better place. But we cannot do this alone; we need your support.”

You can then move on to describe what you need from the audience you are interacting with. And if you have more time (for example, a longer presentation or training), you can also add a slide explaining how you do this (e.g., assessing risks, creating policies, training people, monitoring).

Once you have your message and pitch ready, you are ready to use your organization to infuse it to impact culture.

Mapping your target audience

You have your core message, but of course, a message is nothing without a good plan to deploy it. As ethics and compliance professionals, we need the support of all functions to make our program a reality on the ground. We recommend mapping a target audience and defining an impact plan, function by function.

This could be a high-level mapping of your target audience groups:

  • C-suite

  • Leaders, managers, and supervisors

  • Gatekeeping functions (human resources, internal control, audit, etc.)

  • Business functions (sales, procurement, etc.)

  • All employees

For each audience group, we recommend listing the key points of analysis that will help you define an impact plan, such as:

  • Maturity level of the target audience

  • Actions expected from the target audience (what you need from them)

  • Gap between where the target audience is today and where you would like them to be tomorrow

  • Actions needed on your end to bridge such a gap

  • Impact of change

  • Priority level

This should enable you to plan and prioritize your actions to maximize your impact on your organization. Within the framework of this article, we propose focusing on how you can concretely impact leaders, managers, and supervisors.

Supercharging the program with leaders’ help

Leaders play a central role in establishing the foundation for a culture of integrity. Indeed, employees are significantly more likely to engage in and adhere to your program when they see that leadership is truly committed. Leaders are key role models whose behaviors their teams will want to follow. They can help carry your message by sponsoring and prioritizing your program. Lastly, they can facilitate the detection of violations. How can we get them to play this critical role?

Engaging leaders

First, engage with your leaders and help them understand the context (what your company faces) and their role in strengthening your program. In turn, they can provide you with valuable feedback, including on risks they have themselves identified, obstacles they see to the effectiveness of your program, or good solutions to help move the program forward. Various tools are available to do so effectively:

  • One-on-one meetings: You can deliver your pitch, explain the context and what your organization faces, and be clear about what you need from them.

  • Group meetings: Grouping the leaders can also be very effective in conveying topic-based updates and help get alignment.

  • Updates to the board and committees: Updating these stakeholders helps get buy-in, input, and ideas, from any external board members who may have experience with different programs.

  • Updates to engage leaders: You can update leaders with quarterly highlight emails that help ensure your leaders are up-to-date and provide them with materials they can use themselves to engage in discussions around ethics and compliance with their teams.

Generally, we want to make sure leaders understand their role. Often, leaders know that ethics and compliance are critical and that they have a special role to play, but they might not be so sure what it is that they should be doing concretely. We recommend being extra clear on the actions required of them. The tools mentioned here are great ways to pass this message. You can also consider providing them with practical guidance, tool kits, or training on what exactly you expect of them. And you can also use short surveys to understand whether they are aware of—and actually performing—the key actions you need from them.

Role-modeling and tone from leaders

And what are those key actions? There can be several, depending on the organization’s setup. The ultimate goal is to build and sustain a strong culture of ethics and compliance and increase the program’s effectiveness. We will focus on three actions we consider to be central to reach this objective:

  • Acting as a role model: Leaders who “walk the talk” earn the trust of teammates and other stakeholders.

  • Sponsoring the program by talking about ethics and compliance themselves: Messages delivered by leaders are significantly more likely to resonate with teammates, thus increasing trust and engagement.

  • Creating an open, trust-based environment: This encourages teammates to speak up and, as a result, facilitates the detection of misconduct.

To enable these actions, we propose the following tool box.

Role modeling

Leaders are expected to role model ethics in everything they do. You can make this visible to the organization by, for example, inviting leaders to participate in leadership panels, including discussions on ethics and compliance. Prepare these in advance, and ask leaders to share moral dilemmas they were faced with and how they reacted. Ensure time for Q&A to allow all teammates to engage with the leaders in these discussions.

We also recommend giving leaders an active role during any ethics and compliance training by introducing the topic, emailing their team ahead of time to stress the importance of the training, messaging their teammates to let them know that they have already completed the training themselves, or sharing their impressions on its importance. Leaders can also be prompted to actively drive the completion of e-learnings within their teams.

Ethics and compliance messaging

We recommend creating a short integrity “Tip of the Month” that leaders can use as talking points to discuss ethics and compliance with their teams. The leaders themselves could collaborate to create self-recorded videos on various topics. (Don’t forget to provide them with talking points to ease their lives!) Such videos can then be used in a variety of settings with different audiences, including ethics and compliance weeks, new policy launches, or accompanying a Tip of the Month message.

Facilitating a speak-up culture

Lastly, leaders can help strengthen your program by listening to teammates’ concerns. You can encourage them to build an environment of psychological safety and ensure they become an “open door” for teammates to report misconduct. You can coach them to actively and respectfully listen to teammates, treat reported concerns seriously, and know when to reach out to the subject matter experts.

Furthermore, leaders are expected to be vigilant. Help them understand what this means by underlining they should not wait for people to speak up but rather proactively and regularly ask teammates if they have concerns, thereby sending a message that speaking up is safe and encouraged. Ensure they know to be vigilant when warning signs are present, even if nothing is reported to them directly.

Incentivizing leaders

Incentivizing teammates—including leaders—proves to be extremely effective. Celebrating the good things may be as powerful as punishing the bad ones (if not more so).

Beyond saying thank you and recognizing the impact they had with their actions, we have in our tool box a few ideas to incentivize leaders effectively:

  • Awards: This is about recognizing exemplary role models in the company, nominated by teammates. Winners could receive a token and recognition (e.g., announced by the CEO).

  • Performance goals: This is about encouraging (or requiring) leaders to cascade compliance goals to leaders in their teams (as well as other teammates). Goals for leaders can include (i) talking about compliance, (ii) recording videos, (iii) sponsoring training, (iv) monitoring speak-up reports, etc.

We hope this tool box will provide you with fresh ideas on how to engage your leaders effectively.

Conclusion

Working on crafting a sharp and engaging message on ethics and compliance is time well invested. This message will allow you to engage your stakeholders to partner with you and be part of the change you advocate. Your organization’s leaders are among the key stakeholders for you to engage. Leveraging them will bless you with strong, influential ambassadors, consistently cascading your message and walking the talk in front of their teams. Ultimately, the network you have created will contribute to deeply impacting culture within your organization.

Takeaways

  • The initial investment made in having a robust message and communication strategy will prove fruitful down the line, as a simple and effective pitch will trickle down the organization and work to impact culture.

  • Working with leaders to supercharge your impact will not only help shape culture at all levels of the organization but also help nurture a culture of trust that enables your organization to prevent, detect, and address issues.

*Pauline Blondet is the Chief Operating Officer for Upright Solutions in Copenhagen, Denmark, and Carolina Silva is the Head of Ethics & Compliance for Bridgestone EMEA in Rome, Italy.


1 Merriam-Webster Dictionary, “brand,” last updated August 25, 2024,

2 Simon Sinek, “How great leaders inspire action,” TED Talk, Newport, WA, September 16, 2009,

3 Oren Klaff, Pitch Anything: An Innovative Method for Presenting, Persuading, and Winning the Deal (New York: McGraw-Hill Professional, 2011).

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