Principled

Listen again | Why E&C needs more momentum behind mobile apps

What you'll learn on this podcast episode

Mobile devices influence nearly every aspect of our lives, including how we learn and process information. So, it’s no surprise that mobile is only becoming more important to ethics and compliance programs—especially when it comes to meeting employees where they are. LRN’s 2022 Ethics & Compliance Program Effectiveness Report confirms this. But how can organizations ensure that they are integrating effective mobile E&C solutions? In this episode of the Principled Podcast, host Carolyn Grace, content writer and podcast co-producer, talks with de Guise Vaillancourt, a lead project manager at LRN who specializes in mobile app development. Listen in as the two discuss how mobile solutions enhance E&C program effectiveness and what mobile considerations E&C professionals should take for the year ahead.

To learn more, download the 2022 E&C Program Effectiveness Report.

 

Featured Guest: de Guise Vaillancourt

de Guise Vaillancourt is a lead project manager at LRN who specializes in mobile app development. In this role, he serves as the main contact between clients and product developers throughout the entire mobile project lifecycle—including design, content, user experience, customization, technical requirements and troubleshooting. de Guise has helped LRN launch over 20 apps for client partners in the last three years alone, thereby playing a significant role in shaping LRN’s mobile offering and its evolution.

Prior to LRN, de Guise worked on apps as vice president of international marketing for 20th Century Fox, where he contributed to development from predominantly the end-user perspective. Before that, de Guise was the executive director of global marketing at Avon Products. There, he managed and led the strategic planning, marketing, and product development for Avon's global product portfolio and built partnerships across 15 key international markets, helping transform Avon’s image into a modern beauty resource. de Guise earned his Master’s in I/O Psychology at New York University as well as a Master’s and B.A. in Macroeconomics and Finance from McGill University.

 

Featured Host: Carolyn Grace

Carolyn Grace is a content writer on LRN's global marketing team and co-producer of the Principled Podcast. She specializes in writing compelling stories about ethics and compliance that resonate across business segments, industries, and personas while hitting critical KPIs for traffic and engagement. Topics she frequently covers include ESG, data privacy and protection, DEI, the role of boards of directors and leadership, corporate training and e-learning, and ethical corporate culture.

Prior to joining LRN, Carolyn was a writer and content strategist at Thinkso Creative, a boutique creative agency in New York City. At Thinkso, she wrote internal and external communications for clients in technology, nonprofit, law, logistics, and financial services sectors. Before that, Carolyn conducted trend research and cultural strategy at Horizon Media, specializing in entertainment, travel, media and technology, health and wellness, and food and beverage categories. Carolyn graduated magna cum laude from the University of Pennsylvania with a B.A. in American History and French Studies and a minor in Journalism.

Listen again | How can we make DEI matter to everyone?

What you'll learn in this podcast episode

Can we make diversity matter to everyone? If so, how can we overcome resistance to dealing with tough topics like racism and gender equality and really change people’s behavior? In this episode of the Principled Podcast, host Jen Uner talks with Senior Instructional Designer Felicity Duncan about a new LRN learning model and how it can drive behavior change to support diversity, equity, and inclusion initiatives. Listen in as the two discuss effective DEI training as well as Felicity’s recent work on the new LRN DEI Program, a comprehensive learning campaign that includes a range of essential microlearning assets.

 

Additional resources:

LRN’s DEI Program provides companies with a multi-faceted training solution—a ready-to-deploy learning campaign with curriculums, asset packs, and customizable courses, plus the option to add bespoke content, learner experiences, and communications campaigns developed in association with LRN’s E&C experts. You can preview some of our most popular course content (just one piece of this program!) by clicking here. 

 

Featured guest: Felicity Duncan, Ph.D.

Dr. Felicity Duncan, Senior instructional designer, believes that training and communication interventions have the power to transform behavior, including driving people toward more ethical treatment of those around them.

Felicity graduated with a Ph.D. in Communication from the University of Pennsylvania. After teaching at the college level for several years, she transitioned to workplace education to have a bigger impact on working adults by providing them with the training they need to truly thrive in their roles. At LRN, she is focused on developing high-impact, behaviorally focused content for the LRN Library. Her most recent project saw her working with the Library team to create a powerful new DEI Program that includes not only LRN’s world-class Inspire courses but also a set of microlearning assets designed to support, reinforce, and guide behavior change.

 

Featured Host: Jen Uner

Jen Uner is the Strategic Communications Director for LRN, where she captains programs for both internal and external audiences. She has an insatiable curiosity and an overdeveloped sense of right and wrong which she challenges each day through her study of ethics, compliance, and the value of values-based behavior in corporate governance. Prior to joining LRN, Jen led marketing communications for innovative technology companies operating in Europe and the US, and for media and marketplaces in California. She has won recognition for her work in brand development and experiential design, earned placements in leading news publications, and hosted a closing bell ceremony of the NASDAQ in honor of the California fashion industry as founder of the LA Fashion Awards. Jen holds a B.A. degree from Claremont McKenna College.

 

Listen again | Creating a culture of privacy matters for GDPR and CCPA compliance

What you'll learn in this podcast episode

The world of data privacy and protection continues to evolve at a rapid pace. From the growing number of US states adopting privacy laws to the growing list of rulings under GDPR, the EU’s General Data Protection Regulation, it’s a lot to keep track of. What can organizations do better to adapt to these regulatory shifts and adopt a greater culture of privacy? In this episode of LRN’s Principled Podcast, host Aitken Thompson talks with Andrew Lachman, the head of legal and data protection officer at Contentstack, about data privacy and protection and how to create a privacy culture in the modern workplace.

Learn how you can get involved in today’s conversations around data privacy and protection with these organizations mentioned:

• The International Association of Privacy Professionals (IAPP)
• Future of Privacy Forum
• TechGC

 

Featured Guest: Andrew Lachman

Andrew Lachman has nearly 19 years of experience in privacy space, having founded the privacy practices committee at Move.com and co-founding the Congressional Tech Staff Association while Legislative Director for Congressman Ted Lieu who represents most of the Silicon Beach area. He is currently Head of Legal and Data Protection Officer for Contentstack after running his own firm for a number of years working with startups and growing companies. Andrew is a co-founder and chair of the LA County Bar Association's Privacy and Cybersecurity Section, a member of TechGC, the California Lawyers Association Privacy Section and has been a member of the International Association of Privacy Professionals since 2007 when he received is Certified Information Privacy Professional certification. 

 

Featured Host: Aitken Thompson

After starting his legal career at Kirkland & Ellis, Aitken became interested in the then-nascent field of educational technology.  He left law firm life and co-founded Thompson Educational Consultants and, subsequently, Taskstream, LLC.  Taskstream quickly became a leading company in assessment and accreditation for higher education. Aitken served as Chief Operating Officer, leading the legal, human resources and finance functions of the business. Beginning in 2016, Taskstream underwent a rapid expansion, merging with five other ed-tech companies in a span on 18 months and, in the process, becoming Watermark, LLC, and creating the “Educational Information System” category of ed-tech.  During this period, Aitken’s legal and HR focus expanded to encompass private equity investment and the transition between primary sponsors, cultural and process integration amongst the various merged entities, and the management and harmonization of legacy client and vendor contracts. 

Listen Again | Cracking the code on effective code of conduct design

What you'll learn on this podcast episode

A code of conduct is your organization’s character and culture written down. It articulates who you are, what you believe, and why you are in business. It also provides a reference for all stakeholders. A reference into what your organization values, and how you live those values. But how do you design and implement a code that communicates effectively? What does “good” look like when it comes to codes of conduct? In this episode of the Principled Podcast, host Jen Uner speaks with Senior E&C Advisor Jim Walton about LRN’s new Code of Conduct Report, which presents a set of best practices in code design and implementation. Listen in as the two unpack the report’s insights from nearly 150 codes of conduct deployed by companies around the world—including codes from 3M, General Motors, and Imperial Brands.

 

Get a free copy of the 2022 LRN Code of Conduct Report today.

 

Featured guest: Jim Walton

Jim Walton is a member of LRN’s Ethics & Compliance Advisory Services Team – with over 25 years of professional experience in corporate, institutional and government settings, spanning the fields of ethics and compliance; environment, health and safety; and energy management.

Since 2002, Jim has been passionately dedicated to corporate ethics and compliance – designing, developing, implementing and enhancing constantly-evolving, comprehensive, best-in-class, global ethics and compliance programs. Jim has extensive experience in writing, producing and communicating codes of conduct and corporate policies; designing, managing and implementing ethics & compliance risk assessments; implementing anti-compliance and bribery initiatives; conducting third-party due diligence reviews; and helping managers at all levels become better ethical leaders.

Jim is a Certified Compliance and Ethics Professional.

 

Featured Host: Jen Üner

Jen Uner is the Strategic Communications Director for LRN, where she captains programs for both internal and external audiences. She has an insatiable curiosity and an overdeveloped sense of right and wrong which she challenges each day through her study of ethics, compliance, and the value of values-based behavior in corporate governance. Prior to joining LRN, Jen led marketing communications for innovative technology companies operating in Europe and the US, and for media and marketplaces in California. She has won recognition for her work in brand development and experiential design, earned placements in leading news publications, and hosted a closing bell ceremony of the NASDAQ in honor of the California fashion industry as founder of the LA Fashion Awards. Jen holds a B.A. degree from Claremont McKenna College. 

 

Listen again | Trust is at stake, and other insights from Edelman’s 2022 Trust Barometer

What you'll learn in this podcast episode

Trust is foundational to business and society, so much so that the global public relations firm Edelman releases an extensive annual survey covering whom and what the public trusts. However, their 2022 Edelman Trust Barometer reveals a concerning insight: people are increasingly more inclined to distrust than trust. In this episode of the Principled Podcast, host Emily Miner explores key findings from the 2022 report, “A Cycle of Distrust,” with David M. Bersoff, Head of Global Thought Leadership Research at Edelman Data and Intelligence. Listen in as the two discuss what drives trust, why public trust in certain institutions is eroding, and how businesses can help rebuild trust moving forward.

 

Additional resources:

Get a copy of the 2022 Edelman Trust Barometer.

Read our blog post on takeaways from this year’s report.

 

Featured guest: David M. Bersoff, Ph.D.

David oversees Edelman Data & Intelligence’s (DxI) global Thought Leadership research including the annual Trust Barometer and Brand Trust studies. In this capacity, he is responsible for questionnaire development, leading all data analysis and insight gleaning activities, and developing new frameworks for understanding trust, credibility, and consumer-brand relationships.

Prior to joining Edelman DxI, Dr. Bersoff spent 18 years as a consumer insight and marketing strategy consultant at The Futures Company. In his last 5 years with the organization, he served as its Chief Insights Officer and was a member of its global board of directors.

Prior to entering the consulting world, David spent 12 years engaged in social science research at various Ivy League institutions, including 4 years as an assistant professor of social psychology and research methodology at the University of Pennsylvania.

 

Featured Host: Emily Miner

Emily Miner is the Director of LRN’s Ethics & Compliance Advisory practice. She counsels executive leadership teams on how to actively shape and manage their ethical culture through deep quantitative and qualitative understanding and engagement. A skilled facilitator, Emily emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with organizations in the healthcare, technology, manufacturing, energy, professional services, and education industries. Emily co-leads LRN’s ongoing flagship research on E&C program effectiveness and is a thought leader in the areas of organizational culture, leadership, and E&C program impact. Prior to joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology.

S7E19 | What is the role of trust in stakeholder capitalism?

What you'll learn in this podcast episode

Is trust the ultimate currency of stakeholder capitalism? If so, how can corporate leaders create a culture of trust inside and outside of their organizations? In the final episode of season 7 on the Principled Podcast, host Jen Uner talks about the role of values in building organizational trust—and frameworks to help you get there—with LRN Director of Advisory Services Emily Miner.

You can listen to the other season 7 episodes mentioned in this discussion here:

• How values inform decisions: Unpacking the role of the CECO
• Trust is at stake, and other insights from Edelman's 2022 Trust Barometer

You can access other materials mentioned in the discussion here:

• Aspen Ideas Fest panel discussion with Ellen McGirt
• Corteva case study
• LRN Benchmark of Ethical Culture

 

Featured guest: Emily Miner

Emily Miner is the Director of Advisory Services at LRN’s Ethics & Compliance Advisory practice. She counsels executive leadership teams on how to actively shape and manage their ethical culture through deep quantitative and qualitative understanding and engagement. A skilled facilitator, Emily emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with organizations in the healthcare, technology, manufacturing, energy, professional services, and education industries. Emily co-leads LRN’s ongoing flagship research on E&C program effectiveness and is a thought leader in the areas of organizational culture, leadership, and E&C program impact. Prior to joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology.

 

Featured Host: Jen Üner

Jen Uner is the Strategic Communications Director for LRN, where she captains programs for both internal and external audiences. She has an insatiable curiosity and an overdeveloped sense of right and wrong which she challenges each day through her study of ethics, compliance, and the value of values-based behavior in corporate governance. Prior to joining LRN, Jen led marketing communications for innovative technology companies operating in Europe and the US, and for media and marketplaces in California. She has won recognition for her work in brand development and experiential design, earned placements in leading news publications, and hosted a closing bell ceremony of the NASDAQ in honor of the California fashion industry as founder of the LA Fashion Awards. Jen holds a B.A. degree from Claremont McKenna College. 

 

 

Principled Podcast Transcript

Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers.

Jen Uner: Is trust the ultimate currency of stakeholder capitalism. If so, how can corporate leaders create a culture of trust inside and outside of their organizations? Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Jen Uner, strategic communications director at LRN, and today, I'm joined by my colleague, Emily Miner, director of advisory services. We're going to be talking about the role of values in building organizational trust and frameworks to help you get there. Emily, thanks for joining me today on the Principled Podcast, by the way, our final episode of this season seven.

Emily Miner: Yeah, thanks for having me, Jen. I'm happy to be here and honored to be rounding out an incredible season on the Principled Podcast.

Jen Uner: It has been a great season, and I think we're going to have an opportunity to touch on some of the folks that we've had on the podcast. To get us started though, recently at Aspen Ideas Fest, Fortune senior editor, Ellen McGirt, asked a great question of her panel. She said, "Is trust the ultimate currency of stakeholder capitalism?" It's how we started our conversation today. I of course will say yes, but recently, you spoke with David Bersoff, head of Global Thought Leadership Research at Edelman, and he worked on the Edelman Trust Barometer. You had a chance to speak with him earlier this season, and I'd love for you to recap for us some of the insights that stood out to you.

Emily Miner: Yeah. I think based on the 2022 Edelman Trust Barometer, which is a fantastic annual look at levels of trust in key societal institutions, business, government, media, I think that the 2022 Trust Barometer report would say that the answer to your question and to Ellen's question is yes, trust is the ultimate currency of stakeholder capitalism. In fact, what Edelman found in their research is that business is the only institution in our society that is trusted, and that's actually a first in the 20 plus years that they have been running this type of study.

Actually, for the second year in a row is business the most trusted institution. That was one of the takeaways from the Edelman Trust Barometer, and that David helped unpack when we spoke earlier this podcast season. Given that, if business is the only trusted institution for the second year running, it really underlines the question, what does this mean for leaders? How can they ensure that business remains trusted?

People are looking more and more to business to help solve or address the problems of the world because we don't trust government, because we don't trust media, because we don't trust NGOs. With that mantle of being the only trusted institution, a lot more is falling on business and specifically business leaders and the expectations for them are a lot higher. I think that that really ... That was a current through the Aspen Ideas Institute that you mentioned through the conversation that took place there.

Jen Uner: It really does put a lot of pressure on CEOs and leaders then. One of the stats that I thought was so interesting was how I think it was 60% of employees, they're basing their employment decisions now on the values of the companies that they're looking at and the positions that companies take around social issues, and of course they expect the company to have a position on a social issue, which I thinks it's a rather new thing. Would you say?

Emily Miner: Yeah. I don't know if it's new in the past few years because I do feel like this has been a trend that I've observed in the research maybe up to the past decade or a little bit less, but it certainly every year seems to get to ... It grows. I think, first, it was a healthy minority of the global workforce or of the workforce in the United States, and now it's tipping to be a majority of the workforce. You see some of this in demographic changes as millennials grow in the size of our workforce and now Gen Zers as they're entering the workforce and the expectations that those two generations have for their employers.

But it's certainly not a concept that millennials invented, but it does seem to be growing. Something that's interesting to me now where despite ... We're potentially heading toward a recession in the United States, and despite that, it's still very much an employee market out there. We're still in the midst of a great resignation, which is now really being more called a great reshuffling because it's not that people are dropping out of the workforce so much as they're leaving their jobs to find better jobs.

What some research has shown is that it's not so much that I can find another job that pays me better, but it's that people are no longer satisfied with the status quo and they're looking for opportunities where they can feel more values alignment, where there's more culture of inclusion and equity in the workplace, where they feel that their company is doing something that's contributing positively to the world.

Those are strong drivers of why people are jumping ship and looking elsewhere. It'll be interesting to see how that shapes the narrative and the importance of values and multi-stakeholder capitalism more generally as we continue to hopefully be coming out of the COVID pandemic and this great reshuffling in spite of some of the more negative trend lines with respect to our economy.

Jen Uner: Yeah. I was just going to bring that up. When you have a business environment that's marred by an economic downturn, that puts a lot of pressure. There's then the business financial pressure on decision-making and performance for the company. Then you layer on top of that some of the social and political challenges that are happening and this need to have a position, and can you have a position on everything? Which are the things that you need to prioritize?

I think often corporate leaders in ethics and compliance, our field, chief ethics and compliance officers, for example, the people listening here, they find themselves in a role of counselor to the C-suite as the company and as leaders are facing these kinds of tough decisions. One of the things that really struck me at that Aspen Ideas Institute conversation was Allstate's CEO, Tom Wilson, was one of the panelists and he spoke about a societal engagement framework. I know you had a chance to listen to his presentation. Can you tell me about their approach to decision-making and how they engage on hot button issues?

Emily Miner: Yeah, absolutely. I am so inspired by this framework, and beyond that, there's so much common sense in it, and Tom Wilson talked about this societal engagement framework as something that Allstate developed a little over a year ago in response tom, he didn't use this word, but a deluge of social issues that were coming their way and that the company was being asked to take a stand on or take a position on, sign a letter that's going to be on the front page of the New York Times or what have you.

It got to this point where they said, "We've got to pause and really think about how we're making these decisions." They developed what they call a societal engagement framework that they run all of these issues or questions through. The way that it starts is, first, as an added outset, how does this issue stack up against our values and the way that we do business? There needs to be a level of values alignment before they'll even entertain going further. But assuming that the issue does, they have four filters, as Tom called it, or you could also think of it as just four questions to ask.

The first is, does this issue or does our taking action on this issue help us better serve our customers? The second is, do we, Allstate, have any institutional knowledge about this issue? Third is, can we affect change on this issue? What is our agency here? Then the fourth is, what impact does this issue have on our employees and our reputation? If issue A passes through all four of those filters, then Allstate will come out and they'll take a public stand, and more than just take a public stand, as in the CEO pens a letter that gets published somewhere, they'll actually come out and lead on the issue, engage on it.

An example of an issue that passes this values track and the four filters is climate change. Allstate, obviously, an insurance company, and we know from science that the rate of forest fires in the west of the United States, for example, in the intensity of forest fires is ... The climate change plays a role in that. Forest fires are burning down Allstate customers homes. Does taking a stand and working to address climate change help them better serve their customers? Well, absolutely. That's an easy one. Do they have any institutional knowledge about the issue of climate change?

Yeah, there's a lot of math and science that goes into determining what policy plans and rates are and the risk of different issues to someone's particular home. They have a lot of institutional knowledge about that. Can they affect change on the issue as a large insurer of homes as well as, of course, other things? Their voice carries some weight. They've worked with the government in the State of California to help shape and advance legislation and regulation, as well as perhaps other jurisdictions at the state level, or nationally as well. Then finally, what impact does this have on their employees and their reputations?

Well, they know that climate change is an issue that their employees care about, and so it passes that filter. One distinction that Tom made that I thought was really helpful was that if an issue doesn't pass through the filters, it doesn't mean that they're not going to do anything with it. One of the examples that he gave was the Supreme Court recent ruling that overturns [inaudible 00:12:54]. Allstate's healthcare plan has always covered abortion care, and given the impact that the Supreme Court decision might have on some of their employees that are located in states where abortion care is no longer an option, Allstate has said, "We'll reimburse the travel, et cetera, for our employees in order to access that care."

They're responding to that issue, but they're not coming out and taking a public stand on it. They're not taking a lead on reversing the reversal, shall we say, because does it help them better serve their customers? Well, they're not a healthcare insurer. Do they have any institutional knowledge about abortion care and the impacts of abortion or access or lack thereof? No. Et cetera. It doesn't pass the filters, but that doesn't mean that they're not doing anything about that particular issue. Having this societal engagement framework is a way for them to bring some discipline and structure and consistency into how they engage on the increasing number of social challenges, political challenges, climatic challenges that we as a global society and as businesses are faced with.

It also tells everybody else, all of their stakeholders, their employees, their investors, their customers, it tells everybody, "This is how we do things. This is our process, and we go through this process." At the end of the day, depending on how you feel about the outcome, at least you know what that process was. I just think it's such a brilliant example of bringing that level of clarity into how they're operating in this multidimensional world and connecting it back to the Edelman Trust Barometer that we were talking about into the role of them as business leaders in fostering trust.

Jen Uner: I think this clarity of where you stand and on which issues is an interesting one, because you can't necessarily stand for everything, right? You need to decide where is it your business, really? I think it's interesting how Allstate has chosen to filter a topic and arrive at a conclusion on it. This whole thing about how do you filter and how do you decide, I just find so fascinating. We had Scott Sullivan, he's the current chief integrity and compliance officer for Newmont Mining. We had him on the podcast with Joe Henry, former US compliance officer for Braskem, and they were talking to Susan Divers on our team.

They were on a recent podcast and they were talking about some of the challenges they've both faced in decision-making, and one of the things that stood out for me was how they both used values to guide their decision-making and to guide their counseling of their colleagues in the C-suite, because they were both leaning into values and those corporate values might be stated differently or might be prioritized differently between the two organizations, they would arrive at different outcomes. Right? One of them would say, "Well, our policy around vaccines and masking is that you've got to do it, and no one's allowed back to the office without it."

Then another organization might prioritize something else that says, "Well, it's up to you. You get to make that decision. You can work from home forever if you need to." I think it's really interesting that values plays a really important part and has a real impact on how corporate policy and ultimately behavior, how that comes to be. I don't know if you could talk to me a little bit about that, because obviously you spend a lot of time consulting on values with companies. Tell me about how that shapes company policy and behavior.

Emily Miner:   Yeah. An interesting byproduct of the COVID pandemic I think has been that ... I perceive that the role of values has grown in prominence in terms of the discourse about the role of values in companies has increased. I think it's because the decisions around COVID are so hard. How do we ... Do people come in? Do they not come in? We're risking lives in making this decision. How do we keep, but we can't employ people if we don't have the money to pay the salaries? We have to keep on producing whatever it is that we produce in some level, but how do we do that? These are incredibly complex decisions.

When you're in a situation where you have to make these really challenging decisions and there isn't necessarily a playbook for it. The last global health pandemic was over 100 years ago. I think a lot of companies have come out and said, "We didn't have a plan in place," because this wasn't something that was anticipated. When you don't have a playbook, or to use terminology that's common in our industry, ethics and compliance, rules or regulations about something, values help to fill that void and they guide us on what we should or shouldn't do as opposed to a playbook or a rule, which says what you can and can't do.

Of course, we need rules, we need regulations, we need to know what we can and can't do and where the lines are. But there are always going to be these unforeseen situations, the variant on the scenario that we didn't anticipate when we wrote the rule, and that's where values come in. I think a lot of leaders, a lot of business leaders turned to their company's values, as well as I'm sure their own personal values, to help them navigate the incredibly complex decisions companies had to make surrounding COVID.

I've read a number of accounts from business leaders that have talked about how helpful that was, and they're talking about values more internally and externally. I hope that that's a lens that business leaders will continue to use as strongly coming out of COVID, and that's at the company level, but it trickles down to the individual employee level too, because most companies offer some type of training or onboarding, or you have a code of conduct or you have policies. We have all of these resources that should tell us, again, the cans and can'ts, as well as the shoulds and shouldn'ts.

But I think it's something like humans can only keep three or five things in their mind at once. We can only remember so much. Having the presence of really strong values where the values actually mean something, they're not just a nice recruitment tool on your website, but they really mean something, that's going to be infinitely more helpful guiding behavior on a daily basis across a global workforce and all the variation that comes with that. I've really been encouraged by how values have become a more dominant part of the conversation in the business community.

You're right, depending on what your values are, you might have completely different outcomes. But again, it comes back to that transparency of the process and the fact that there is a process, the structure of the process that, at the end of the day, most of us can get on board and accept what it is because we understand how we got there. That's what I think is so key. It's just that transparency on how we got there. It's not so much about the end as the journey, so to speak.

Jen Uner: Yeah. That makes total sense. I know in our code work, in the consulting work that you do with our clients, speaking of employee level work, we often include frameworks for decision-making, right? That work at the employee level. What are some examples of these tools that can help not just leadership, like we were just talking about a societal bigger picture one, but on the individual level? How does that play out?

Emily Miner: Yeah. Actually, after watching Tom Wilson talk about Allstate's societal engagement framework, I actually went online and just Googled Allstate's code because I was curious, how do they ... do they have something similar, a similar framework that they share that they've developed for their employees? In fact, yes. In their code, they have a whole section on ethical decision-making that lists nine questions that employees should ask themselves when they're faced with a decision or a situation where the decision or the course of action is unclear. Is it legal? Okay. Yeah, that's an obvious one, but does it conflict with our values?

What are the consequences of this? How would your family and friends perceive this decision or course of action that you take? These are some of the questions that Allstate included in their code that I think we ... The majority of us could probably take any number of tough, sticky, gray area situations and go through it, and is it legal? Okay, well, maybe I'm ... I don't know the law, but how would I feel if my mom knew? How would I feel if this was on the homepage of CNN? We all know how we would feel about that, and that's such a helpful ... It connects to our humanity, the human heart level.

It's just really helpful framing that Allstate's providing to their employees. We help a lot of companies write their codes of conduct. Ethical decision-making models or a code in and of itself is a guide for behavior and breaking out different risk topics into what are the behavioral expectations, et cetera. But having a decision-making framework or a list of questions or whatever it is that ... It's issue agnostic, it's situation agnostic, it's just something that anybody can pick up and use. That continuity of Allstate at their company level, as well as how they translate that down to employees, it is just something that I wanted to note.

But it's something that we include in most of our codes that we create for our clients. Some of my favorite examples, one of them is John Deere. Their code is beautiful, and it's who they are. It's their culture written down, which is what we always strive for. They include a decision-making framework as well and it include ... There's a series of questions and it's an interactive. You ask yourself this question and then you click yes or no, and it reveals guidance for what your next step is. But also, it starts out with is it consistent with our values? Centering the values first and then going into consistency with rules.

They also ask, "Would this build trust with employees, customers, shareholders, or communities, or would it harm trust?" That is how we started at the outset of this conversation around the importance of trust in the business context. Similarly, how would I feel if my actions became public? Et cetera. They have their own framework that's speaks to their culture and to their values. Another example is Corteva, which is an agriscience company, and they also have a framework. Theirs is a little bit different. It asks a series of questions, and then depending on how you answer those questions, they give guidance on who you can consult for advice, and it's going to be different depending on the situation.

That's also nice that you're not on your own, right? There are others in our organization that are here to help and can help, and if it's this situation, contact this group, and if it's this other situation, contact this other group. I also thought that's something that they did a little bit differently. They're all different. You talked about the conversation in the earlier podcast, but the goal is the same, which is to provide guidance for behavior that is reflective and supportive of who we are as an organization, what we stand for and what we value.

Jen Uner: It's really, really important. One of the things that we know from our Benchmark of Ethical Culture, which is a report that you were very involved in, and it certainly steers a lot of my thinking these days. We know from the Benchmark of Ethical Culture that the companies with the strongest ethical cultures are going to outperform their peers by up to 40% in key business metrics, the standard things that you would want to have as a business like employee loyalty, innovation, adaptability, customer satisfaction, and growth.

I think that taking code of conduct seriously, taking value seriously and taking culture building seriously is probably one of the most important things that a company could be doing right now, especially when you look at the Edelman Trust Barometer and the role companies have to take right now in society. Trust becomes super foundational to that. I know you've got some insights that you can share around trust building and how foundational that is for ethical culture.

Emily Miner: Yeah. When we conducted our research into ethical culture globally in a business context, we looked at ... I want to say 10 different dimensions of culture and how people and organizations behave and operate, and we did some fancy statistical modeling to look at are there some aspects of culture that are more important than others? How do they relate to each other? What drives what? And all of that. What we found was that there were some dimensions that rose to the top in terms of influencing other elements of culture, as well as those business outcomes that you talked about, and trust was one of them.

We found that trust had an outsized impact on whether or not people behaved ethically in an organization, and particularly when they were under pressure. I think that that's such an important idea because if you look at any number of corporate scandals, so often, not in every case certainly, but in many cases, the pressure to perform that was set out or pushed by the organization, by leaders in an organization, is part of why people did what they did.

This idea that trust is one of the strongest drivers of whether people behave ethically, especially when under pressure, I think is a big one that certainly makes me sit up a little taller and take notice, because it's something that any chief ethics and compliance officer would say that they're looking for and is a goal of their program. Another area where trust really stood out as a driver of employee loyalty, we were talking earlier about the great shuffling, but I think that also makes it stand out even more for me, just in our current context. People are more likely to stay in your company, you're more likely to retain great talent if they trust you as leaders, as an organization, their peers, and if they feel trusted themselves.

Jen Uner: I think one of the things that was evident too in the research is the value of transparency and building trust.

Emily Miner:   To wrap up a lot of the threads that we've talked about and as it relates to transparency, one of the findings that was so compelling to me from the Edelman Trust Barometer was that the majority of people are expecting CEOs, specifically CEOs, to take a public stand on any number of social issues of our times. But at the same time, at least in the United States, these issues have become so politicized and polarizing. That's a tough bar to set for CEOs. How do they thread that needle? It's why I think that Allstate's societal engagement framework is just so brilliant, because it helps them figure out how are we going to address these issues?

Responding to that majority of the population as Edelman, found they're looking for Allstate CEO and for any number of other companies' CEOs to take a stand. It's a way to respond to that call without politicizing or polarizing or without politicizing the issue, because that's not what it's about. It's not about is this a liberal cause or a conservative cause? Is it a Democratic cause or is it a Republican cause? It's four questions. Does this help our customers, do we know something about it, do we have agency over it, and what impact does it have on our employees?

It really takes all of that noise out of the decision-making. I just think it's such a great example of how leaders in general can take up that mantle of society's expectations of business to help solve and address our social issues without having that response fall into any political trap that's going to alienate you or with your employees or with customers. It's such a great example and one that I hope other business leaders take inspiration from.

Jen Uner: Well, I think it just really speaks to how important it is to set up those frameworks in advance so that you're not caught in panic mode or in defensive mode when it's not even necessary to be that way. Right? If you've set up those mechanisms in advance, you're going to probably come out ahead because you will have already created a framework that's going to prioritize the human response.

Emily Miner: Absolutely. Absolutely. Because what's the next COVID? What's the next unexpected thing? To already have that framework in place is going to be so helpful.

Jen Uner: That's why we say rules are good, values are better.

Emily Miner: Exactly.

Jen Uner: Goes back to that. Emily, thank you so much for joining me on the Principled Podcast today. It's our final episode of season seven, as we take a summer break and we'll resume with season eight in September. In the interim, we'll share encores of our favorite episodes from this season. To close out. My name is Jen Uner, and I want to thank you all for listening to the Principled Podcast by LRN.

Outro: We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance in global organizations by helping them foster winning ethical cultures rooted in sustainable values. Please visit us at lrn.com to learn more. If you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcasts, or wherever you listen, and don't forget to leave us a review.

S7E18 | How values inform decisions: Unpacking the role of the CECO

What you'll learn in this podcast episode

It’s generally accepted that effective E&C programs are based on values as well as rules. But applying those values to real-life situations can be difficult. This has been particularly true during the pandemic, as organizations make hard decisions in many instances and chief ethics and compliance officers play a key role in guiding those efforts. How can values help CECOs sustain ethical performance—and even excel—in the face of such change and adversity? In this episode of LRN’s Principled Podcast, host Susan Divers talks with Scott Sullivan, Chief Integrity & Compliance Officer at Newmont Corporation, and Joe Henry, who just retired as US Compliance Officer at Braskem. Listen in as they discuss the difficult choices they faced in providing moral leadership in their organizations—how those choices were made, by whom, and what the examples say about the role of the CECO.

 

Principled Podcast Show Notes

• [1:58] - Scott’s role as the CECO at Newmont Corporation, the challenges faced and how he applies his values.
• [4:50] - Ethics and compliance at the heart of Newmont’s decision making during the pandemic.
• [6:10] - Joe’s role at Braskin and the challenges he faced.
• [11:20] - The role of Joe’s values in influencing colleagues to change the decisions they made.
• [13:35] - The lessons learned from these tough experiences in the company.
• [16:12] - How both company’s ethical cultures emerged after the pandemic. 
• [19:50] - Other circumstances which strengthened the respective ethics and compliance cultures.
• [27:25] - The most important areas of focus for an ethics leader in resolving difficult questions.

Featured Guest: Joe Henry

Joe Henry was the US Compliance Officer for Braskem, a multi-national Chemicals and Plastics company headquartered in Sao Paulo, Brazil.  He led the Ethics, Compliance and Risk Management efforts for Braskem’s US operations including commercial, manufacturing, logistics, management and Innovation and Technology (R&D) functions. 

Prior to joining Braskem in January 2017, Joe was a Compliance Director at GSK, a global pharmaceutical company, and worked in various ethics and compliance roles since 2003.  Investigations oversight, Compliance Operations, Methodology development, process assessment and improvement, policy and procedure management and managing government oversight programs were some of the responsibilities he successfully fulfilled while at GSK.  Prior to his GSK Compliance roles, Joe worked at SmithKline Beecham as an Information Technology Project Director and with IBM Sales, Technical Support and Product Development. 

Joe earned a B.S. in Chemical Engineering from Carnegie-Mellon University and an MBA from Saint Joseph’s University.  He also earned his certification as a Leading Professional in Ethics and Compliance from the Ethics and Compliance Initiative (ECI).  Joe and his wife reside in Lewes, Delaware and he retiredg at the end of March 2022 to pursue personal interests, travel and enjoy more time with his 3 grown children and two grandchildren.  Joe continues to provide advisory and investigation services on an as-needed basis to Braskem’s US Compliance department.

 

Featured Guest: Scott E. Sullivan

Scott E. Sullivan is the Chief Integrity & Compliance Officer of Newmont Corporation, the world’s leading gold company. Newmont has approximately 15,000 employees and 15,000 contractors and has 12 operating mines and 2 non-operated JVs in 9 countries. Mr. Sullivan oversees, develops, implements and manages Newmont’s integrity and compliance program including ethics, anti-bribery, corporate investigations, and global trade compliance. Previously, Mr. Sullivan was the Chief Ethics & Compliance Officer of a global manufacturer of fluid motion and control products with approximately 17,000 employees operating in 55 countries. Mr. Sullivan has written and contributed numerous articles on compliance programs, anti-bribery/FCPA, export controls, economic sanctions and other ethics and compliance topics to a variety of publications. Mr. Sullivan is also a frequent local, national and international speaker, moderator and conference organizer on compliance, anti-bribery/FCPA, export controls and economic sanctions.

 

Featured Host: Susan Divers

Susan Divers is a senior advisor with LRN Corporation. In that capacity, Ms. Divers brings her 30+ years’ accomplishments and experience in the ethics and compliance area to LRN partners and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance and substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance.

Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program.

Mrs. Divers’ background includes more than thirty years’ experience practicing law in these areas. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.

Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008.

She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics. Mrs. Divers’ most recent publication is “Balancing Best Practices and Reality in Compliance,” published by Compliance Week in February 2015. In her spare time, she mentors veteran and university students and enjoys outdoor activities.

 

 

Principled Podcast Transcription

Intro: Welcome to the Principled Podcast brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers.

Susan Divers: Hello, it's generally accepted nowadays that ethics and compliance programs that are effective are based on values as well as rules, but applying those values to real life situations can be difficult. This was particularly true during the pandemic when organizations had to make hard decisions in many instances in unprecedented circumstances, and ethics and compliance officers frequently played a key role in guiding those efforts. How can values actually help ethics and compliance officers sustain ethical performance and even excel in the face of change and adversity?  

Well, hello and welcome to another episode of LRN's Principled Podcast. I'm your host, Susan Divers, director of thought leadership and best practices with LRN's advisory group. Today, I'm joined by two thoughtful ethics and compliance professionals, Scott Sullivan, the chief ethics and integrity officer at Newmont Corporation, and Joe Henry, who just retired as the US compliance officer at Braskem. We're going to be talking about the difficult choices they face in providing moral leadership in their organizations, how those choices were made, by whom and what the examples say about the role of the chief ethics and compliance officer. Scott, I'm going to start with you. Can you talk about your role as the CECO at Newmont and some of the hard choices you've faced and how you applied your values?

Scott Sullivan: Sure. And thank you, Susan. It's exciting to be part of this podcast and it's a subject I'm very passionate about. So while Joe will be tackling some specific examples, I thought it might be more beneficial to start with a bit on process and approach. So when your values are tested in trying times, this is when the rubber meets the road. So the least common denominator approach, or what is accepted, what is condoned, often becomes your culture. It's not the pronouncements and the platitudes, but rather what you do on the ground or in crunch time. So during COVID, which by the way is not yet over or gone, we faced numerous challenges like everyone else, our values of safety, responsibility and integrity were at the forefront of what we did and said every day. As our strategy rolled out, we had to consider the full spectrum of stakeholders from vulnerable indigenous communities in which we operate to suppliers who were dependent on us to our employees.   

In some cases in the early days of COVID, we even went into what's known as care and maintenance mode, which is basically shutting down except for essential services to protect the health and wellbeing of a variety of our stakeholders. We also deployed over 20 million in a COVID fund to assist communities around our minds with COVID type issues and challenges. We were active partners in the COVID struggles. We protected our employees with PPE, with vaccines, with health checks, et cetera, all this being said there were numerous and oftentimes competing opinions on what to do, being strong proponents of our values, and always circling back to them as a gut check when we made decisions, some of them which might have turned out to be controversial, was an excellent moral compass. It made us focus on not just what the short term, but what the long term was and what the consequences could be, both the good and the bad. It was our collective corporate decision that we had to make.         

As a compliance team. Part of our job was trying to read the tea leaves and anticipating what was coming. Fortunately at Newmont, we have a fantastic executive leadership team who gave us the space to support them and the organization this endeavor. We invited in diverse perspectives, we had spirited debates and we pressure tested key decisions that mattered most. I'm proud of the approach that we took as an organization whereby no means perfect, but I think it has served us quite well.

Susan Divers: Scott, before I turn to Joe, one of the things that strikes me about what you just said is it sounds like ethics and compliance was really at the heart of decision making in these difficult areas that you mentioned. Am I reading that right? And if so, how did you achieve that?

Scott Sullivan: Yeah, I think, health and safety for sure was I think the heartbeat, if you will. Perhaps we were the supporting role, but really as COVID evolved over times, the issues got more complicated as they went. So you had initial true health and safety issues, in some cases life and death that you had to do, but then you had a whole series of decisions around employment, around vaccinations, around care and maintenance. And what do you do with communities, where the donations go? How do you ensure that you're not supporting corruption when you're doing the good deed of making donations? So I think as COVID evolved and as the challenges around COVID evolved, we became more integral and more integrated to those decisions over time.

Susan Divers: Well, and that's really a good example of how it's meant to work. Yeah, the ethics and compliance department isn't defective if it's often a corner, but it is effective if it's right at the heart of difficult choices, and that's a perfect segue to Joe. Joe, do you mind outlining your role at Braskem and then talking about some of the actual challenges you faced in your role in those?

Joe Henry: Certainly. Thank you, Susan. Thank you for the invitation to join you all today. Let me start off by saying that Braskem leadership team is a caring and forward looking group and primarily based in the US headquarters in Philadelphia. And that information will be important in a minute or two. Early in the pandemic two of our sites operated for 28 days via a live-in where our workers stayed on site, quarantined from family and other outsiders to operate our plants in Pennsylvania and West Virginia. These plants produce polypropylene, which is a key material for personal protection equipment, such as surgical gowns, face, shields, gloves, and masks. So our workers were willing to do that. And our Braskem leaders provided all the essentials for this live-in. And our team members were paid for every hour on site.

So Braskem tries to do the right thing. And during that time, all other team members were directed to work remotely during the pandemic. Eventually after our operations were deemed essential to US business interest, all of our plants reopened with strict masking and quarantine requirements, including restrictions in travel. One of our first policy decisions developed in Philadelphia was to require workers to quarantine for 14 days after travel if they had traveled from their home county. Works for Philadelphia were pretty close around in the urban area. The policy, and it worked for salary team members who could work from home, but not for hourly workers who worked on site and who would not be paid for the time they must quarantine. So at our Texas sites, this policy was problematic in that it would not be unusual for a worker employee to travel to the next county to care or check in on a family member. Therefore, compliance was asked to intervene. And as a result of that, our intervention, we extended the travel range and only had the policy applied to travel outside usual circumstances.

The other one is more around vaccines. So one other example as vaccines became available, again, I remember they were under emergency authorization. There became a drive by Braskem management to encourage team members to be vaccinated and to push required team members to be vaccinated or else be terminated. The impetus for this requirement was that several people at manufacturing sites were complaining about being vaccinated and still having to wear a mask because others were not vaccinated. We discussed the proposed requirement at the leadership team meeting, which US compliance is a part. And then there was actually a discussion in our industrial team where we're not a part and they mandated this vaccination or termination requirement by a majority vote, not a consensus vote.

I received a call from one of the dissenters. He was concerned that many of his employees would resign or be terminated because they did not trust the vaccine yet. His plant would be greatly affected. I brought this to the attention to the US leadership team that the vaccines were not yet fully approved and that no matter how administratively burdensome the CDC's recommendation was vaccination or regular testing. So I informed the group, I thought our requirement was overly restrictive. It infringed upon employees' rights, and I would not approve any of these terminations, in the US, the US compliance officer approves all terminations. So I had some leverage there. So what happened is we implemented weekly testing for team members who were not vaccinated. And that seemed to resolve the situation. By the way, it was helpful that I was fully vaccinated and boosted and it was clear, my personal beliefs were not a factor.

Susan Divers: Wow. That's a very striking example, Joe, there's a couple of things I'd like to pursue a bit. One is, it's clear that people brought you into these decisions that they turned to you as a resource, it sounds like certainly in the case of be vaccinated or terminated before the vaccines were fully approved, but also it sounds like you were asked to intervene on the travel restriction. Is that correct?

Joe Henry: Yes.

Susan Divers: And was that at a senior, if I can ask, or other level?

Joe Henry: I would say the vaccination or termination decision was a senior management at one of our industrial sites had the concern. And then the travel policy was probably, as I recall from one of the HR leaders at the site saying, Hey, we have some employees that are in unique situation here, or maybe not so unique, but different than what we would have from an urban center versus someone working in a more rural area.

Susan Divers: Well, that's another good example of how a compliance and ethics and compliance program should work. It should be a resource and be welcomed into decision making, particularly on very difficult and tricky issues like the two that you just described. Can you talk about the role of your values in convincing your colleagues and your leadership to change or moderate the decisions that they made?

Joe Henry: Absolutely. That was probably the driving force is our code of conduct, we don't dictate to people how they must behave, especially outside of work. It's fortunate that US compliance and compliance department of Braskem is independent and we're objective. And we're very visible. So people know us and people are willing to approach us. Again, that's why I started off the leadership team, it had the best of intentions. They heard from one group that says, Hey, we're tired of wearing masks. We want to be productive. And they reacted to that without understanding the potential consequences and the potential issues they may have with our own code of conduct. And that we couldn't mandate someone put something that was not yet fully approved. And that actually went further than what the government was telling us we needed to do. Which isn't uncommon. Our policies and procedures are frequently tighter than what the law requires. But in this case, we had to recognize that people have freedom of association and freedom of choice about theirselves. Once we brought all the potential consequences and perspectives of all affected team members, I think we reached the right decision.

Susan Divers: So was that a difficult process, would you say, was it time consuming, or once you played that role of honest broker, was it something that people widely accepted?

Joe Henry: Yes. Yes. I would say, we did use a lot of influence in... Basically had the show them what the consequences are, why their actions might not be entirely appropriate. So it wasn't a matter of authority. It was a discussion and it was a lengthy discussion, but I think everyone was fairly open minded and recognized that it was going take some more work and maybe we were going to have to spend some more money, especially getting a company to do the testing for us on a weekly basis. But I think they quickly arrived that it was the right decision.

Susan Divers: Well, that's a great example. And thank you for sharing that. I'm going to go back to Scott for a minute and then to you Joe and ask. So obviously these were pretty intense situations that you dealt with. What lessons did you learn from that experience given your role in the company? If you could discuss that a bit, that would, I think be very helpful.

Scott Sullivan: Sure. Yeah. Building on my prior comments a bit, I would say there were a few learnings and perhaps a few aha moments that we recognize along the curve. I think one was, you need to think both long term and short term. So whether it's your employees or your stakeholders, you might have a decision today that is different than the consequences tomorrow. So really making sure you're not just stuck in the moment, but you're thinking about the long term of the consequences or actions that come out of your decisions today. Playing off one of Joe's comments about culture and values, modifying a Warren Buffet quote a little bit, "Values take a long time to build, but they can be destroyed in a heartbeat." And people watch, I think that's the one that organizations often forget when they're looking at their culture, it's that whatever you allow or condone becomes your actual culture.

So I think it's really important to practice what you preach and stay true to those values or before you know it, or right under your nose, you lose them. And that's true, perhaps even more so in the darkest days. So, how you're treating your employees and what people did with respect to terminations, or extending compensation during COVID, all eyes were on that. And I think that has longterm consequences for employees is they think, well, how did my employer treat me during those dark days? Did they exit us from the organization? Did they treat us poorly? Was the mighty dollar, the only thing that mattered? And again, for us, we have a social license to operate in the locations we do. So you have to think about that holistically, the full ESG perspective and look at all your stakeholders.

And I think a little bit about what we've been talking about as well is anticipating the pushback, where are those pressure points, or focal points that are likely to come up and figuring out, like we always say, you can't take a program off the shelf, but customizing or figuring out what works best for you? And then hopefully that leads to you and many more in your organization becoming both values, beacons and champions to help the organization propel forward.

Susan Divers: So in other words, it really can become a tremendous positive as long as you stay true to your values. And you're actually strengthening your culture, not destroying it to go back to the Warren Buffet quote. And Joe, based on your experience, do you think that your ethical culture at Braskem emerged stronger as a result of the types of difficult choices that people made in those circumstances? And are there any other lessons learned from that, that you would want to highlight?

Joe Henry: So I believe our culture has gotten stronger. The ethics and compliance group and officers know they need to stay ever vigilant to ensure that passions do not overtake the organization's foundational values. We live in an impatient society that is quick to react and does not always consider all perspectives and unintended consequences. So this experience gives us an opportunity to talk to the leadership team and say, Hey, let's take a breath here. Let's look at this. I think when you're more thoughtful about these decisions, I think the decision will be better, probably strengthen your culture versus weaken it, or undermine it. But I do know that my successor's still facing these challenges.

Susan Divers: Yeah. Although you're building ethical muscle at the same time, I want to highlight what you said about stop, pause, think, or you said it a little differently, but our chairman of our board, Doug Sideman, has written extensively about the benefits of pausing. And we do live in a impatient world and one that moves at light speed, particularly with social media. And I think Scott, you would agree with this too, that stopping and getting everybody to slow down and look at all the potential ramifications and equities. Joe's example of employees in Pennsylvania versus employees in Texas, I think is a very telling one. And that, that is really, I think what's needed to deal with particularly moral leadership issues. Scott, does that make sense? And also if you could talk about whether your ethical culture came out stronger as a result of the pandemic, that would be helpful.

Scott Sullivan: Yeah. I think you often see in some areas the short term view or this, in the impatient world, as I like the way Joe characterize it, you see the pitch forks and the torches coming out in any particular topic. And so part of our job is to say, let's pause, let's think this through, the unintended consequences, the longterm consequences, I think for sure our ethical culture has emerged stronger. It really gave us ample opportunities to do the right thing and to put theory into practice. So one of the things coming out of the tragedy of COVID is it really gave us an opportunity to show our values and do the right thing in those dark days. And I think that also that consistency of messaging and values, it's not one offer. There's one big case. I think that really builds trust with stakeholders and gives you an opportunity to show that you're a different kind of company.

So even in the dark days with bad or troubling news, you're going to be transparent and that we stand true to our values and hold ourself accountable to those values. So that consistency of operational model, I think extends well beyond ethics into business and health and safety. When faced with a challenge, we're going to think about it, be very thoughtful in what we do and ultimately do the right thing for the entirety of the stakeholder community.

Susan Divers: Yeah, that sounds like very sound holistic decision making. Joe let's let's switch gears a little bit. We've talked about the pandemic and the challenges and how both of you feel that your ethical culture got stronger as a result, and you both played pivotal roles in the ethics and compliance programs, played pivotal roles in helping your organizations navigate. Can you give some other examples outside of the pandemic of having to do that?

Joe Henry: So I mentioned one of our values is the freedom of association. As a result of the summer of 2020, George Floyd death and all, we had some outsiders, some activists and DE&I consultants recommend some potential path forward for the company. One of those, including tracking managers' social media profiles, and other forms of public expression and see whether they should continue to be leaders in the company or not. For instance, should we sanction a manager for attending a pro-life rally, or another manager for posting their support for the police on their Facebook page? That type of monitoring is not aligned with our code of conduct. We declined that recommendation. Again, the passion was there. Hey, we got to weed these people out. Well, no, we have to make sure that when they're working for Braskem, they're aligned to Braskem's values and that they're not diminishing our name in the public.  

And then most recently we've discussed how and when should compliance be involved in handling microaggressions. And we've agreed that microaggressions are supposed, should be handled between the two people in the first instance, maybe in a second or third occurrence, that it's handled, the person's called out publicly. And if it's repeated, then it's no longer a microaggression, it's an aggression. And then it comes to human resources or compliance. But those are some of the choices where, again, we relied on our code of conduct and relied on our proven policies and procedures regarding our ethics line to preserve the culture and continue to move the company forward and evolve the company.

Susan Divers: Well, and that's another excellent example of pausing and looking at all the ramifications and carefully analyzing whether it is consistent with your code or not. Scott, do you have similar examples outside of the pandemic experience?

Scott Sullivan: Yeah. So we've been on a journey of what I would probably call radical transparency in the ethics and compliance space, so where we're willing to show the good, the bad and the ugly to advance the health of our culture. It is a journey, so we're not perfect by any chance, but we're now more transparently and willing to share internal stories and struggles with our employees. I used to laugh all the time that most companies will say something happened to somebody, sometime, someplace with some result. And that leaves everybody, what the heck is that? What happened? And what are the expectations I know? So we've decided that we want to clarify expectations for employees. We want to at least establish the baseline for ethical behavior. And we want to ensure really that fraudsters or predators are held to account in the organization wherever and whenever we can. And also there's an evolving view about when something happens in our organization, what do we do to ensure that those individuals or groups of individuals are not just set free and allowed to go into the general community and repeat those damage?    

How many times have we all learned in the compliance profession, individual moves from company A to B, to C to D. And when you do the investigation, there's a long track record that history being repeated at different organizations. So we have done cradle to grave exposes, including one with a public press release, where we actually lifted the hood and told the full story. So most times it's fairly detailed internally and the reception has been excellent. It's advanced our culture ball pretty dramatically. As I mentioned, that being said, it's really, we're still on the journey, but we feel that practicing what we preach and not allowing performance to excuse misconduct or cornerstones of our culture.

So even when the outcome is internally painful and extremely disappointing, we've been trying to promote this. So it's not just you do it once, because you can't fake it. And if you do it once, you see big scandals in organizations and periodically it's a big splash in the paper. And we've had similar things where you've had a case that we did our first radical transparency case. And I think the organization, the employees were saying, okay, is this a new way that we're going to operate, or is this the company's hand was forced and they felt they had to do it, so they did it? And so I think that whole concept of you can't fake, it's got to be genuine, it's got to be demonstrable and it's got to be sustainable, is really important.

And as an aside, I think most companies can get compliance correct, or they get it right. That's to say that it's the right side of the brain, it's the math science side. It's one plus one, plus one equals three. But when you get to integrity, you get to ethics and culture, that's the equivalent to me, the left side of the brain, it's the English history. It's a little bit more soft. It's touchy, feely. It's hard to measure, but I think it's far more impactful. And that is often where I see organizations fall down, because it's so hard to do. And it's so hard to say, what is it? And it feels like it's subjective, or judgemental, or it's just real hard to do. So I think companies that focus on getting the integrity or the culture piece right, are so far ahead of the curve and getting everything else right. And that's not just in the ethics and compliance space, because I think that could be a proxy for good governance. It could be something that is a springboard for doing other things in an extraordinary way or well above peer organizations.

Susan Divers: That's so interesting that you framed it in those terms. Something we talk about a lot and we're not alone in that in this area is that you can't just look at your ethics compliance program as a checklist and say, I'm good to go because I've got policies, code, training, audit, it has to be living and breathing. And that's where the touchy feely comes in. And the research, interestingly, it shows that if you have organizational justice where you're holding people to the same standard, and I hear you both talking about that in what you've described today, then you have the lifeblood and a strong foundation for your ethics and compliance program and activities. But if you don't, if there's two standards of justice, or what I'm hearing today too, is if there's a rush to judgment where some people get trampled in that rush, then you don't really have a strong foundation for your program. Joe, would you agree with that as well?

Joe Henry: Yes, I absolutely do. Yeah, it has to be thoughtful, fair. We haven't gone to the extent from a transparency as Scott Newman have us to naming particular people, but we do anonymize those situations and publish them or even present them as lessons learned.

Susan Divers: Yeah. That's very powerful. Well, we're starting to run out of time, but two questions before we terminate, which is what are the most important areas of focus by an ethics leader in resolving difficult questions? You've both given great examples of how central ethics and compliance was to tough decisions. But if you're a relatively new ethics leader, what are some of the key things to really bear in mind when those tough issues come up? Scott, you want to lead us off on that?

Scott Sullivan: Sure. So I think as we've both mentioned, and same with Susan, the tone at the top is really important. So getting your executive leadership on board, otherwise the likelihood of success drops pretty dramatically. And I think as we've also both said, relationships matter. So build them wherever and whenever you can. And I think it's always that rainy day fund, you build credit in the bank, you build street credit. So for the bad news bear moment you have to come in, I think that's really important. So they understand who you are. You're not just a cry wolf person, you're thoughtful, you're methodical. You do all the things the way the organization would expect.

And I think, for all of us, unfortunately, and you can see the business partnering go too far. So I think not withstanding that you always have to remember that there will be times undoubtedly as a compliance officer, where you have to put your neck on the line and hopefully your organization does not have a kill the messenger culture, that's not a fun organization to be a part of. And I think value based decisions are toughest in downturn markets and during crises. So we've come out of a pandemic and now we're going into what seems to be a downturn market. So I think the key message there is really prepare in advance and look at your rainy day credits and figure out where you're going to have to put your stake in the ground and move forward.

Susan Divers: So build up your relationships and your credit and your goodwill. Joe, something to add.

Joe Henry: I do that. I wholeheartedly agree. I think that what Scott mentioned is the most important area, but another area of focus is the company's values, which usually describes in the organization's code of conduct and implemented through your policies and procedures. And I remind the executives and our team members, employees, the code of conduct and policies are approved by the board of directors after thorough and thoughtful review by the executives, by the stakeholders and by compliance. So they're not done instantaneously and there's a lot of thought, there's a lot of reason why we have them and they shouldn't just be dismissed quickly because the particular circumstance. These documents provide the desired ethical direction of the company and have been very useful in resolving difficult decisions in the past, especially with well-meaning, but passionate team members. Go back to the foundation and consider it maybe, maybe, maybe we do need to make a change to the code of conduct or a change to our values, but at least reference it and have that discussion before taking any severe action that may have unintended consequences.

Susan Divers: That's a very good point. One of my colleagues describes the code of conduct as your culture written down, and using it as a focal point and a way to ensure that major decisions and discussions include values, I think helps make it a living and breathing document. Well, this has been such an insightful conversation. I wish we could continue it talking about tough choices, I think is really helpful for people at whatever stage they are in their ethics and compliance journey and profession. So I want to thank our listeners. My name is Susan Frank Divers, and we'll see you the next time on Principled Podcast. Thanks Scott. Thanks Joe.

Joe Henry: Thank you.

Scott Sullivan: Thank you all.

Outro:   We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principle performance in global organizations by helping them foster winning ethical cultures, rooted in sustainable values. Please visit us at LRN.com to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcasts, or wherever you listen. And don't forget to leave us a review.

 

S7E17 | Campaigns, not courses: Why communications matter to corporate training

What you'll learn in this podcast episode

Good training is not quick to create. It takes time, effort, and years of instructional design experience. And too often, best-in-class training gets derailed by inadequate communications. An effective, attention-grabbing communications strategy is just as important as the quality of the learning itself. How can companies ensure that they’re designing training and communications that produce positive learning experiences and—ultimately—business outcomes? In this episode of LRN’s Principled Podcast Damien DeBarra, leader of Curriculum Design and Communications Strategy at LRN, and Tomaso Manca, learning director at LRN, discuss the importance of intentional curriculum design when developing corporate onboarding. Listen as the two talk about what best practices organizations should consider in their approach.

 

Principled Podcast Show Notes

• [1:28] - What is meant by the idea of campaigns, not courses?
• [3:47] - Best practices for incentivizing learners.
• [6:11] - The benefits for learners.
• [7:31] - How does LRN approach this campaign-based strategy?
• [9:46] - Examples of ways to retain the attention of your audience.
• [11:54] - Tactics used by LRN to bring the idea of campaigns, not courses to life.
• [15:00] - Tips to ensure people don’t feel overwhelmed by your campaign.
• [17:30] - The LRN difference in this approach.
• [20:40] - Advice for people looking to implement this approach for the first time.

Featured Guest: 

Tomaso Manca has created exciting learning events for more than 20 years. As a Learning Director at LRN, he works with clients to create engaging learner experiences that support behavioral changes.  Before joining LRN, Tomaso spent more than six years as a Learning Manager at Interactive Services. Prior to that, he worked as Best Practices Global Learning Manager at Thomson Reuters, supporting the learning of their Sales Organization.  Tomaso holds an M.A. in Economics from Yale University.

 

 

 

Featured Host: 

Damien DeBarra brings more than 20 years’ experience to the instructional design and strategic workforce planning spaces.  As a Senior Advisory Learning Solutions Manager at LRN, he focuses on creating training solutions that ensure business buy-in and connect hiring practices to day-one learning roll-outs. In the last few years, Damien has helped organizations such as United Airlines, Sun Life Financial, SITEL, Astellas, MFS Investments, and SAP create 90-day action plans for their solutions and develop supporting communication strategies. He has worked with over 200 clients in areas ranging from retail to pharmaceuticals, call centers to nuclear plant manufacturing. Prior to LRN, Damien spent more than nine years as the Learning Solutions Director and Head of Instructional Design at Interactive Services. He has also worked as an instructional designer at NCALT, Electric Paper, and Epic. Damien received his BA from Maynooth University.

 

 

Principled Podcast Transcription

Intro: Welcome to the Principled Podcast. Brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers.

Damien DeBarra: Good training is not quick to create. It takes time, effort, and years of instructional design experience. Best in class training is too often ruined by inadequate or authoritarian style communications. An effective attention grabbing communication strategy is just as important as the quality of the learning itself. So, how can you ensure that you're designing training and communications that produce positive learning experiences and ultimately positive business outcomes? Hello, and welcome to another episode of LRN's Principled Podcast. I'm Damien DeBarra, the leader of curriculum design and communication strategies at LRN.

Tomaso Manca: And I'm Tomaso Manca, learning director at LRN. As co-host for this episode, we are going to be talking about the importance of intentional curriculum design when developing corporate onboarding, and what best practices to consider in your approach. All right, Damien, let's dive in. Something I've been hearing a lot at LRN is the idea of campaigns and not courses. What do we mean by that?

Damien DeBarra: So campaigns, not courses, it's taken from the name of a talk we did recently at the Learning Technologies Conference in the UK just a month or two ago. And it's reflective of a conversation, which we have a lot here at LRN, which you hear in production, in our delivery teams and in the advisory team where I work. And that is the... We often semi-jokingly refer to it as, "the tragedy." "The tragedy" is that, we see world class learning materials being delivered to the business with a sort of, "or else" style communication. So if you think about it like, the client comes to us and says, "look, it's really important for us to roll out this training initiative around..." For example, B E and I, we make them a world class e-learning course. We develop a brilliant interactive classroom version of that for those who can't do online.

We animate fully bespoke, beautiful videos. There's a whole plethora of support materials ready for the learners to help apply to the job. And the people who've partnered with us are really super psyched and can't wait for the business to get at this. But then the email goes out saying, "Hey, do this course by Friday, or else." It's devastating to your efforts, because as we sometimes like to joke a little bit, people who take online training, particularly online training, they're a little bit like people who ring call centers. And that is that they're already slightly irritated before they get to you. And if you do anything to give them an opportunity to opt out, to give them an opportunity to let that email slide down the inbox and just be ignored, they'll likely grasp it. And it's not because people don't want to learn on the job, it's simply that it's one email and another hundred inside of the day. They've probably got a job to do. They've already got training. They might be behind on... So any kind of blunt order to do a course really doesn't help. So instead, what we try and do is catch people's attentions and then incentivize them, or if you like, seduce them or draw them towards actually exploring those learning assets.

Tomaso Manca: Very interesting, Damien. Can you share the best practice for incentivizing learners?

Damien DeBarra: Sure. Well, we tend to do it slightly differently for... with each client, with each partner and differently for each communication strategy, depending on what's being taught or what needs to be learned. But there does seem to be an emerging best practice and it is nascent, it's really emerging, but that is the move away from what you might call the one and done training deployment towards a more campaign based approach. Campaigns, they're spread out over slightly longer periods of time. The amount of minutes a learner spends in their chair doing the training should be the same, or if even possible, less than whatever they did the previous year. But the campaign is spread out rather. And it's made up... The idea is use microburst trainings and snappy communications. Really engaging videos, try and keep them under one minute, two minutes, maximum. Job aids with exploratory questions to help you focus, and then whatever the medium, whatever the channel, we try and focus on using simple repeated messaging across a period of time in multiple channels. 

And if possible, we try and get that messaging going through the business, not just from an actor, as aware in a voiceover, but rather from real people within the organization. So real people within that business, diverse voices and if possible local leaders. So it brings a degree of authenticity to it, but again, back to that idea of, we need to catch people's attention. So whatever communication it is you're sending out around your training launch, it really needs to get people's attention. It has to stand out from the other 99 emails that you might have received that day. The response we want is, we want people to see a headline in an email and go, "oh, what's that?" And click to open it. And it's... It is about drawing people in and avoiding the language you normally associate around training. The very instructional designer language, the very people and culture departments. So human resources department's language, moving away from all that language around learning and trying to make it sound and feel not like training but more like a marketing campaign for something really cool. That's going to make you better at your job.

Tomaso Manca: So we're talking about using language that draws the learner in, within a campaign based strategy. What are the benefits for our learners?

Damien DeBarra: Well, there's a number of them, as we said, the first one is to try and take the sting out of being asked to do training when you've already got a multiple... a long series of tasks to do in your day. So as we said, we know people, a lot of people... if we give them an opportunity to leave that email alone, they will. Also... I alluded to this a couple of months ago, that language of instructional design we're all kind of used to hearing, "by the end of this course, you will be able to..." Whilst that has its place, if we can use a different kind of tone and approach, what you might call a more magazine style of writing, it's much more human. It's much more relatable. And it benefits the learner because, basically we want to try and increase and drive engagement.   

So it's about trying to make the materials not sound like training, it's something that's going to be where you're being talked at. And the benefit of the learner is, as I say, primarily engagement. Keep them guessing, kind of engaged in thinking, "what's going to happen next? What's this about?" You've told them there's something in it for them, but using good copywriting and clever headlines, and also simple questions to draw people into wanting the answers to those questions. So the benefit, I'd say probably in summary, if you were to reduce it to one word, it would probably be engagement.

Tomaso Manca: And how does LRN approach this campaign based strategy?

Damien DeBarra: Well, like I said, it's different for every partner, but there are common tools. So, the idea is to have a carefully targeted communication strategy that is, we determine what the core messages are that we want in the comms campaign. We determine when we want to release them. Not everything should go out at the same time. And we want to repeat those as a series of simple focus messages through multiple channels. So yes, the email is the obvious one, because that's... things go to the inbox. It's the primary point to contact, but we also like to use internal communications channels. So for example, if you're within the Microsoft Office environment, as many of our clients are, let's start pushing stuff through Microsoft teams or through Yammer or through Slack, if that's where your environment is for internal discussion.

And also, it doesn't have to be digital. So for example, we create off, sometimes physical assets. So posters that go on walls in common areas within manufacturing environments is a classic one. Tent cards that sit on tables with a QR code. Again, seductive headline. "What's that about?" You take your phone out, maybe scan a QR code and it launches you to a 62nd advertisement about the campaign. So we do it a multiplicity of different ways, but the idea is that we work with you, your partners and communication specialists within those partners, to create a calendar strategy that's tailored for your needs. It's about getting the right messages and the right headlines delivered in the right channels. It's important to spread the messaging across different channels to make sure that we hit everybody in as many places as we can, at the same time as trying not to oversaturate the business with too many communications. So it's a bit of a balancing act between those two things.

Tomaso Manca: These are great points, Damien. I think it's important to make sure, as you were saying, to cut through the noise. Ensure that the learners hear what they need to hear in a form that resonates and connects with them. You want to engage and excite people, as you were saying.

Damien DeBarra: Exactly. You do. You want to engage and excite people. And in fact, I'll just throw the microphone back to you for a second and ask you. You've written stuff like this as well, and had a lot of experience of this at the deployment level, at the individual communication level. Could you give us a couple of examples of what that looks like tactically? Some of the approaches and ideas you've used.

Tomaso Manca: Well there are a few things to keep in mind, first of all, talk about real people and real issue that will resonate with your audience. And use messages that are simple and direct. For instance, with a client of ours, a large multinational food conglomerate, we have scheduled design workshops that focus on creating targeted messages. Representatives from the target audience are invited to each workshop and they help tailor the message and provide immediate feedback on whether the message will resonate with their peers or not. You also want to deliver those messages using multiple formats to ensure you capture the attention of your audience, something you already touched upon. A good example is a communication program you are creating for a large chemical company. Every month, we generate a message that fits within the client's larger communication initiatives. And so far we used a variety of medium.

We use graphically announced email blasts. Actual poster to be placed in the client's office, and short videos. We plan on adding podcasts and user generated video content next. And speaking about medium, the choice of medium barriers depending on the message and the desire to impact. You want to ensure that the content and the format go hand in hand, that they're aligned and true to your brand, your voice and your audience. The feedback we keep receiving from our clients is that these tips really help engage in their audiences as the messages come across as relevant, flexible, and timely. I know I covered only a handful of examples, so I'm going to bounce it back over to you then and ask you, what additional tech do we use at LRN to really bring campaigns, not courses, to life?

Damien DeBarra: So it's a little bit of the kitchen sink approach. Our strategies leverage the full LRN toolkit. So we've mentioned multichannel approaches like, using emails, using online training, but we also can design virtual classroom events. There's the email and comms campaigns I've mentioned. Internet, banner adverts, SharePoint, or WordPress built websites, to back up the training materials. But we also have our... We have a campaign manager tool, which allows you, the client, to log into the LRN platform, plan out the entire comm strategy, put all the copy... and schedule the entire thing, to send out the emails or the comms at exactly the time you want weeks and months in advance. And it enables you to do a load of work up front and then sit back and let the system take care of it. Ultimately, we can write the... work out the comm strategy for you, write the copy and the headlines and provide the visual assets, and then hand them over to the partner to deliver themselves.

This is a 50-50 split on what partners want. Some want to control that release themselves internally, and others want us to do everything for them, or have a tool that does everything for them. But we use everything, job aids and videos, microsites. Also help lines, chat channels in teams and Slack and other tools like that. And then crucially there's one overlooked thing, which is leader accountability programs. In the past, we've grandly called this, the accountability principle. And that's a slightly fancy pants way of saying something quite simple but very important. And that is... That if you bring leaders into the process of the training, it has a dramatic effect. So if you consider the two... the following two ideas... following two communications, "Hey Tomaso, I want you to do this training course by the end of the month."

That's of relative interest. If I say in the communication, "Hey, Tomaso, I need you to do this training by the end of the month." And one week afterwards, your leader slash manager is going to have a conversation with you about this for 10 minutes. I think your interest level, your amount of skin in the game dramatically increases. And an even better version of that is, "Hey Tomaso, do the course." Now then you're going to talk to your leader, "and by the way, this affects, or connects to your annual performance review." That's a really powerful incentive. So, a leader accountability and leader involvement, or just general accountability for your participation in training is very, very powerful. So it nudges the learner, we think, from being potentially passive, into a very active role within their own learning journey.

Tomaso Manca: I could see that having clear incentives linked to the overall job performance is a very powerful motivator. I really like, also, the imagery you used of the kitchen sink approach. And I'm also thinking that some people might hear this expression and worry that it could lead to information overload. What are some tips to make sure that people don't feel overwhelmed by your campaign?

Damien DeBarra: Yeah, it's a really important concern because it can go too far. I saw a campaign recently we were designing, when it was getting out of hand. We were sending out, potentially discussing sending out 8, 9, 10 communications around something which was actually only a 30 minute training course. And that's probably far too excessive. So you have to work with the partner to make sure that we're not overdoing it. And also, it's about being judicious and careful in what you say in the communications. So two obvious things to say, the first of which is, if you're sending somebody an email about a training initiative, make it short. Make sure that the email is written as snappily, and as eyecatchingly as the training should be written itself. And then the second thing is, if you're worried that people are getting too many communications and there's too much training and too much time spent on training is a common complaint we hear.     

Actually make a virtue of the issue of time. So for example, you can say to the learner, "put the time into the title." So let's say something like, "the 20 minute code of conduct training." Okay, that's a very awful title, but put the time into the title and say something like, "invest 20 minutes in doing this now. And you'll be prepared for your annual review." "Spend 30 minutes on this training course, and you'll be able to do this, this, and this in your job." So again, it's back to what you and I often talk about the whiffing. The, "what's in it for me?" Explain to the learner how much time... how little time you want them to spend. In fact, "look, we've reduced it to 20 minutes, because we've heard you, there's too much training. It's taking too long. We heard you, it's now down to 10 minutes every month."

So again, if it's a campaign and it's spread out across a quarter, rather than asking them to do a 40 minute course, tell them, "you're going to do 10 minutes every week for the next four weeks. And as a result, you're going to be safe in your job. The company's going to benefit and you'll be ready for your performance to do... and you'll be able to serve your customers and our communities and our shareholders." And so on. So I would say if you're worried about them... if the partners expressing their concern or you have a concern about there being too much time spent on this, or if it's just overload, make a virtue of talking about how it actually saves time in the long run.

Tomaso Manca: Makes sense to me. And when it comes to this approach, what do you think is the LRN difference?

Damien DeBarra: So I could probably talk to you all day about tech and campaign managers and our disclosure tools and how there's a lot of technology to talk about. But actually, sometimes I think that the power of good copywriting can't be underrated. So we deploy a lot of cutting edge technology to drive solutions, but sometimes the most powerful tool we've got is one simple eye-catching headline. So we know, as we've just been discussing, that learners are time poor. They're training wary, so we place a strong emphasis on getting their attention using snappy headlines to drive people to the training assets.

Tomaso Manca: Interesting. Can you share some more examples of successful copywriting?

Damien DeBarra: I can probably share a few headlines. I won't name the partners themselves, but one springs to mind is, Large North American Financial Firm. That's as far as I'll go in describing it. And their problem was, very much like we were just discussing, learners getting way too many communications around having to do training. The communications were a bit on the blunt side, borderline rude in one or two... in cases. And learners were telling us via data in surveys and in focus groups that they were just really quite fed up with this. So the approach we took was, we knew that we had to get their attention in five to 10 seconds. Getting their eyeballs or they were gone. So what we did was, we opened up a campaign, and the first email in the campaign, the headline said, and it was deliberately written in capital letters.

It said, "I can't wait to do compliance training this year." And then when you clicked on the mail, the next line was, "said, no one ever." That's the headline to grab your attention. And then the next thing is, it said, "we hear you. We've got it. You've told us through focus groups that it's taking too long to do training. So what we've done is, we've reduced everything down to 20 minute buckets per quarter or per month." I think it was. Another example was, from the same campaign in fact, was that, for reasons which aren't entirely understood or there seems to be a different set of reasons for different clients, fishing scans spike in August and September. So what we did there was, we sent out an email. I think it was in August and the headline in that one was, "you are a danger to yourself and others."

So deliberately provocative headlines. And there's about 12 different subjects in that communications campaign, but they all took that approach. I hesitate to call them click bait headlines, because that's an awful term, but it was something designed to make you go, "what? What's that?" And hopefully you click. Again, that principle of having got their attention with the headline within 30 seconds or even 30 words. You should tell them in the first paragraph this is why you've clicked and this is what you're going to get and how long it's going to take you to do it. And again, that thing, the whiff and "what's in it for me" explaining that, if you do this, it will make you better at your job, et cetera. So getting their attention and explaining what the value is for them.

Tomaso Manca: And I can see that it all boils down to writing. Damien, you've touched... certainly you've touched on a lot of great points about the value of taking what we are calling a campaign, not courses, approach. And I think this will inspire a lot of our listeners to consider for their own training. So what advice would you give to people who are looking to implement this approach for the first time?

Damien DeBarra: Well, at the risk... That's a great question. So at the risk of potentially starting with something negative, get ready for resistance. A lot of the times the heartbreaking thing we hear sometimes when we're talking to our partners is, I kind give them this pitch and then they say, "that's brilliant. That's never going to work here." See, it's that classic line. "That's fantastic, now let me tell you why I won't work for our company." And it's because a lot of people are wedded to the particular calendar of release at one time of the year. And we understand that's a necessity for certain partners and clients, particularly if it's a very big program. We understand why they might want to get it all done in one quarter so the learners don't feel it's dragging on over the year. But if you have one particular smaller training initiative, you might consider that campaign based approach, but get ready for resistance.

People will be skeptical about it. Some folks just won't want to do it. You also, when you get into doing communications around this, you'll also need to bring in other partners from across the business. So traditionally, if you're the training manager at a company, small to medium enterprise, I don't know, a couple of hundred staff, the training department might be you... might be just one person. But now you're talking comm, so you've got to bring in your communications team. They have their own calendars. They have their own priorities for things that need to be communicated to the business. And a common one we hear is... from our learning and development partners is, "that's great, but the communications team are already telling me there's too many communications." So get ready for that conversation. Get ready to try and influence the other stakeholders in your business to understand the benefits of taking this different approach.

And to do that, you might try and arm yourself. This is easier said than done. Too massive, right? But you might try and arm yourself with a case to make that change. And that's in the form of some data. So are you able to get a survey from your current learners on... let's say on your last year's training on, how your learners liked it? Get that survey data. Now that might be painful because that survey data might reveal that they really don't like the training and it can be hard not to take that personally. And you might think to yourself, "do I really want people in the business scene, the feedback we're getting?" And an even more powerful... Sometimes in addition to a cluster of data from a large number of learners, is anecdotal information taken from focus groups. So a classic trick... not trick, but a classic approach we've done a few times is to bring in a group of learners into a focus group. Keep the training and development people out of the room. That might sound cruel, but you want people to feel free to speak freely. And of that five or six people, you might have a bit of a spectrum of learners. That is saying a couple of learners who have been in the business a number of years, who'd probably be training wary, that might be a bit tired of all this.

And maybe a couple of learners who are newbies who've just gone through the training, have not yet been at the company long enough to be completely drawn into the culture, and they can often give you very fresh observations. So I suppose what I'm saying is, get ready to have the conversations and get ready for that resistance, but also try to strike a balance. As I said, if there's a possibility you can overdo this, where you can go hog wild, go crazy and start communicating to the business on everything. And that can become even more irritating than the blunt once a year communication. So there's a balance to be struck all the time. I hope that answers your question. Not sure I have.

Tomaso Manca: Oh, absolutely. It does. And it opens up a lot of other questions. You and I can probably be talking about strategy for the rest of the day, but it looks like we are out of time for today.

Damien DeBarra: Yeah, we should probably wrap it up. And it's always great talking to you about this stuff Tomaso. Thanks for the time.

Tomaso Manca: Likewise. And thanks to our listeners. My name is Tomaso Manca.

Damien DeBarra: And I'm Damien DeBarra. And I'd like to thank you all for listening to the principal podcast by LRN.

Outro: We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance in global organizations, by helping them foster winning ethical cultures, rooted in sustainable values. Please visit us at LRN.com to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple podcasts, Stitcher, Google podcasts, or wherever you listen. And don't forget to leave us a review.

 

S7E16 | How Hershey’s mobile app hit the sweet spot for engaging E&C

What you'll learn in this podcast episode

According to LRN’s 2022 E&C Program Effectiveness Report, 56% of the respondents said that integrating major program elements into a mobile app was a high priority for them this year. But what does a “good” mobile solution look like? And how can you ensure it strikes the right balance of meeting compliance needs while creating an engaging—and helpful—user experience? In this episode of LRN’s Principled Podcast, Carolyn Grace, content writer and podcast co-producer, discusses E&C mobile solutions with María Fernanda Castañeda Zavala, the ethics and compliance manager at Hershey. Listen in as they explore how Hershey leveraged a mobile app to enhance the components, capabilities, and overall brand of their E&C program.

 

Featured Guest: 

María Fernanda Castañeda Zavala serves as the Ethics and Compliance Manager for The Hershey Company. She is responsible for driving the ethics and compliance program effectiveness and awareness across the company. She leads the implementation of training, communications & outreach, policy lifecycle management, monitoring, case management, and co-leads Hershey's Ambassador program.

Prior to joining Hershey, she was Ethics and Compliance Analytics Program Manager at Nokia, where she led initiatives to collect, analyze and visualize data to test compliance controls, enabling data-driven decisions to drive continuous program improvements. She holds a Master of Business Administration degree from Montclair State University, New Jersey, and an Accounting bachelor's degree from Escuela Bancaria y Comercial, Mexico. She is a Certified Compliance and Ethics Professional-International (CCEP-I) and a Certified Business Analyst.

 

 

Featured Host: Carolyn Grace

Carolyn Grace is a content writer on LRN's global marketing team and co-producer of the Principled Podcast. She specializes in writing compelling stories about ethics and compliance that resonate across business segments, industries, and personas while hitting critical KPIs for traffic and engagement. Topics she frequently covers include ESG, data privacy and protection, DEI, the role of boards of directors and leadership, corporate training and e-learning, and ethical corporate culture.

Prior to joining LRN, Carolyn was a writer and content strategist at Thinkso Creative, a boutique creative agency in New York City. At Thinkso, she wrote internal and external communications for clients in technology, nonprofit, law, logistics, and financial services sectors. Before that, Carolyn conducted trend research and cultural strategy at Horizon Media, specializing in entertainment, travel, media and technology, health and wellness, and food and beverage categories. Carolyn graduated magna cum laude from the University of Pennsylvania with a B.A. in American History and French Studies and a minor in Journalism.

 

 

Principled Podcast Transcription

Intro: Welcome to the Principled Podcast brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change-makers.

Carolyn Grace: If you want your ethics and compliance program to meet your employees where they are, you need to take mobile seriously. And most E&C professionals know that. In fact, 56% of the respondents to LRN's 2022 E&C Program Effectiveness Report said that integrating major program elements into a mobile app was a high priority for them this year. But what does a good mobile solution even look like, and how can you ensure it strikes the right balance of meeting compliance needs while creating an engaging and helpful user experience?

Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Carolyn Grace, content writer and co-producer of the podcast at LRN. Today. I'm joined by María Fernanda Castañeda Zavala, the ethics and compliance manager at Hershey. We're going to be talking about how Hershey leveraged a mobile app to enhance the components, capabilities, and overall brand of their E&C program. Fernanda is a real expert in this space with a background focused on compliance analytics and monitoring. Fernanda, thanks for coming on the Principled Podcast.

María Fernanda Castañeda Zavala: Thank you for having me, Carolyn. I'm glad to be here talking about our journey and our ethics and compliance program.

Carolyn Grace: I've really been looking forward to this conversation with you as I've been hearing nothing but success stories coming out of Hershey's mobile E&C solution. For those who aren't as familiar with your story, can you start by sharing what Hershey's ethics and compliance program was like before the app came along? What were the challenges or opportunities you wanted to address at the time?

María Fernanda Castañeda Zavala: Certainly Caroline. Well, at Hershey, we are a purpose driven organization and our ethics and compliance program is designed to promote an organizational culture that encourages ethical behaviors and lives our shared values of togetherness making a difference, excellence, and of course, integrity. Our program overall is guided by a suit of carefully crafted policies and processes developed to keep us competitive, prepared and resilient. Back in 2020 and motivated by the 2020 DOJ compliance guidance, one of our priorities in the program was to understand how our colleagues were interacting with our set of policies, our code of conduct and general information that we were putting together around our program. Our goal was to be able to measure our program effectiveness. So various data points to identifying trends, patterns, KPIs, or potential gaps.

At that point, we used to have our policy library on the internet and had the limitation that we weren't able to get any insights on the number of views or searches in the code or our policies. We were looking to streamline the process to providing training, access to our concern line, that's the way we call in Hershey, our helpline, our code of conduct and overall, the policy information. That is when we thought about having all in one place that could allow us to have metrics and provide all resources in a consolidated way. We were conscious that we wanted to do it in a way that allow our colleagues to get our information in easy to access way and ideally, on the go. We know that a good part of our workforce is not in front of a computer the whole time. And we're looking to ensure they have the support needed at their fingertips, an easy way to ask for help when required. That is when we realized a mobile app with the correct capabilities would allow us to achieve this goal. And we did our research and start working toward this objective.

Carolyn Grace: That makes a ton of sense. I think, especially hearing you talk about the ease of access and being on the go, we are in a 21st century workforce. There's no surprise there that many people are away from desktops and laptops and using their mobile devices. So your logic behind building this program into a mobile app makes a ton of sense. So let's talk about the mobile solution itself. What did you ultimately build into your E&C app and what was your reasoning behind choosing those particular elements to achieve the objectives that you were just talking about?

María Fernanda Castañeda Zavala: Perfect, yes. So as I said, we wanted to monitor our effectiveness. So our goal was to have one stop shop for ethics and compliance needs. That is why we focused on some elements that were core to our program and we wanted to make sure all of them were included in our app. Those elements are our code of conduct, our policy library, our reference guide library, or job aid library. We needed to have a direct access to our concern line and either access to our learning management system to allow our colleagues to complete their trainings on ethics and compliance, or any training overall throughout the app. And we also wanted to have a direct access to our monitoring processes, like for example, disclose a conflict or any of the processes that we have in place in the program.

We were able to design an app that is user friendly, easy to navigate and where employees can find the content in their local language. That was also an important inclusion aspect that we wanted to ensure in the app. As an example, the code of conduct is organized by section. So the end user is able to go directly to the area of interest or search on any specific content. Let's say, if I am looking to understand the company's stand on retaliation, I can go to the specific area or search by the term and the app will provide me all the resources available around that topic. Our user interface is set up in English, but the end user can select the language they want to see the content in. So we have that flexibility built in, in the app. For example, if a colleague based in Mexico will like to see all the content in Spanish, they are able to do so, selecting their preferred language and the content in the language is automatically showed.

For us, it was important to include languages, to empower all employees to have the and compliance information in their fingertips. The app also helped us to consolidate in one place, all monitoring processes, as I said, that we have in place. Our colleagues don't need to look around in the internet or different portals to find where to disclose a potential conflict, where to declare some hospitality or any of our processes. They can get into the app and find the proper links there.

The app is also a way to facilitate access to our LMS. Our colleagues can complete their trainings from their mobile phones or tablets. These greatly benefits employees that are not in front of a computer all the time, as we just highlighted. Overall, one of our main objectives was to measure program effectiveness. And with analytics available on app usage, we are able to identify what areas of the code most are most the most viewed, the terms most search. So we are able to take action and draw out campaigns or produce content that answers the questions that are being asked. It is important for us to highlight that, although we do analytics in the app usage, we do not connect any consumer or customer data. The app is designed to host our library. And the only information we get is a number of view and search terms. That is enough to give us visibility on the data we wanted to see, to understand our content impact.

Carolyn Grace: That is a really great clarification point for sure. And I love that I'm hearing all of these elements of personalization that you have really built into this app. Not only in terms of languages that people can engage in with this content, but also the actual content itself that they are engaging with. One of the things that always interests me about mobile app development as well is the branding, and how organizations really lean into making the app their own. I'm curious, what were some things that Hershey did to help make the app look and feel connected to the wider company?

María Fernanda Castañeda Zavala: I think that you hit a very important point. Branding is important when you are developing your app or customizing your app. That is why the first thing that we did during the development of the app is sharing our company visual guidelines. We connected with our communications team and they provided the color codes and imagery that will ensure Hershey look and feel within the app. Our company already has other apps for different purposes. That is why we wanted to provide a similar experience in the ethics and compliance app.

The next step that we took is it was to define the name of the app itself. For that purpose, we also wanted collaboration. Therefore, we asked for the help of our peers and we launch an internal survey asking for suggestion on the title of the app. And we received a variety of creative names, but we selected five that resonated the most.   

And the selection went then into a poll, where we asked for votes and the winner was selected, and our app it's called iComply. Once we had the name, we went back to our talented corporate communication designer, and she came up with our app logo, which matches our program brand and is aligned with our corporate visual guidelines. The development team in LRN made further customizations to make the app feel in line with our brand, delivering consistent brand identity across the wider organization. It was without doubt, a very collaborative process and we needed to relay a lot in our internal resources to have the proper branding within the app.

Carolyn Grace: That's great. And I love that you went to the people of Hershey to really get involved in this process and contribute to what ultimately became the brand of your ethics and compliance program. I think that only speaks to the even bigger importance of a company's brand, it's made up of the people who work there. So I love that particular element of your process. So I'm sure at this point, our listeners are now eager to know what the impact of all of this has been. What are some interesting results that you've seen, quantitative or qualitative, since adopting this mobile app?

María Fernanda Castañeda Zavala: Well, right after the implementation, we got a very positive reactions from our leadership, our colleagues, and our compliance ambassador network. From a quantitative perspective, we saw a very good adoption rate in our workforce. 40% of our corporate employees reviewed the app and it's content at least one time in the first six months, after the implementation. We compared this with other companies within the industry and it came out to be a very good adoption rate, ratifying that having all resources in one place was a real necessity. We were able to identify that our reference guides or job aids were the contact consulted the most. So that informed our decision on how to best convey our compliance guidelines to our colleagues.

We now understand that another important part is the use of notifications. The app enable us to send a short message to all our users, reminding them of the important aspects of the program, or invite leaders to discuss videos or reference guides with their teams that we have available in the app. And appropriate use of notifications, I must say, allows you to drive adoption, maintain awareness, engagement, and send tailored messages to your teams.          

As the use progressed, we identified areas that we needed to include in the app. For example, we were able to connect our legal chatbot to the app. Now, employees can navigate in the app and get redirected to the chatbot and get the immediate assistance they require. One of the other comments that we got right at the beginning was that the app needed to be available for tablets. So we raised that right away to the developer. And now we have the app available in that format too.

Carolyn Grace: That's fantastic. And I mean, wow, what an adoption rate for your app. I have spoken with a member of LRN's mobile development team on a prior episode of this podcast, actually, and we were talking about adoption rates. So to hear that it was 40% is just incredible. And again, to hear that you were taking direct feedback from employees using the app to further iterate on the development is just really exciting to hear. It sounds like this was a highly iterative process, which I am sure is just another day in the life for ethics and compliance program managers like yourself. What are some key insights you learned from this work and how can they inform the way E&C professionals should approach mobile?

María Fernanda Castañeda Zavala: That's a great question. I think that overall, planning is key. And you first need to understand your needs and set goals that align with them. If you have, for example, a workforce that's on the go and do not have a computer all the time in front of them, you may want to consider having a mobile option for them. Once you have clarity on what you're looking to achieve, do your research. And building an app might seem a big challenge, but if you have a clear idea of what you want to include and what are the pain areas you want to ease with an app, the task will be easier. As I said, planning is key.

When developing our app, we made a list of areas that we wanted to cover. We collaborated with our IT team to ensure we will be able to connect our LMS and the security required within the app. We brought our communication team, as shared before, in the planning stage to ensure we had the correct branding. We talked with our HR team to make sure we included the the correct policies in the app. And at the end, it was a cross functional collaboration. And I would say that's another key area, cross functional collaboration is key. That collaboration also paid off when we look to connect our chatbot. IT has been a key partner to help us make that happen.

Another important area that we might consider is simplicity and user friendly. These are other key components to consider. If you decide to have an app, it should be easy for the end user to navigate and explore the content. That will help to ensure engagement with the users and secure awareness. You also have to consider to be agile in the process. In our program, we strive to keep relevant content in the app, make regular reviews of your content to make sure it still serves your purposes and update it as necessary. That will make sure that you send notifications about the changes or the updates and it will ensure that users are engaged and are really checking and reviewing the content in-app.

Carolyn Grace: That makes a ton of sense. And I think what you just mentioned about simplicity is so essential here. You and I, and so many of our listeners are using mobile apps every day, and it's no surprise that the ones we don't use as frequently tend to be ones that are too complex. And with something like an ethics and compliance program, I'm sure it can be very easy to want to put everything in there. But that cross-functional collaboration that you were just talking about I'm sure is what ultimately helps figure out, okay, what is the most essential pieces of information and features that we need to get that program message across and to ensure that is as effective as possible? So I think that's a really great point to make.

I mentioned at the top of our episode, that one of the key findings from our 2022 E&C Program Effectiveness Report was that more than half of respondents said integrating major E&C program elements into a mobile app was a high priority for their program in the near future. What recommendations would you give to those folks who are just starting out with this?

María Fernanda Castañeda Zavala: I would say that similar to what, what I shared before planning is key and knowing your program is key. Ethics and compliance tends to be a complex area, where you need to convey messages in an easy way for employees to adapt and understand and follow. So if you want to have an app that your colleagues will use, definitely you have to make it simple and have to make the content engaging enough so people go back and see the usefulness of the app. Having a mobile option for all employees to consult policies and procedures, I think it's a great advantage that must be considered. Before we were recording this podcast, PR came to me and mentioned that she normally, when she has some hesitation about a procedure or a process, she normally goes to the app and quickly reviews the section that she needs to clarify and find it easy and really fast way to just check one or two points on the go.

So I think that if that's something that you're willing to achieve, explore the possibility of having the app. Do not be afraid that it's going to be a complex situation, but do make a plan. And also consider that if you want to have an mobile application for your ethics and compliance program, that this application, it's part of your communications calendar or your overall year strategy. When you combine campaigns that you do with the trainings and you send notifications throughout the app that all, the whole experience or the whole idea, it's very cohesive and allows employees to have an overall idea of the environment and the usefulness of the app.

So have that in mind whenever you want to explore the possibility of mobile app. And then again, simplicity, be agile, look for a functionality that allows you to update the information that you have there quickly and in an easy way so that it does not turn out to be cumbersome for you being updating the information in that app. That would be my main recommendations because I think it's a great option and a great tool that ethics and compliance programs can leverage from.

Carolyn Grace: Absolutely. And you make such a great point, that ease of use in the app is not just for the end users. It is for the program managers and it and admins who are putting material in the app as well. So all the more reason to keep it simple and streamline the process as much as you can. That communications aspect as well, I think is a great point to highlight for folks because to your point, ethics and compliance programs are so much more than training or just the code of conduct, it really is about the whole experience of the program. And so highlighting the use of notifications, I think is a great point when it comes to communicating key elements of your program. Fernanda, I think that we could go on and on and on about the importance of mobile apps to E&C programs, but unfortunately we are out of time today. But thank you so much for sharing these insights with me and keep up the great work at Hershey.

María Fernanda Castañeda Zavala: Thank you so much. I think you're right, we could go on and talk for a long time. But thank you for having me and for this opportunity to share our journey and lessons learned.

Carolyn Grace: Yes, absolutely. And thank you all for listening. You can learn more about the importance of mobile solutions by downloading a copy of the 2022 Ethics and Compliance Program Effectiveness Report at LRN.com, or by clicking the link in our show notes. I'm Carolyn Grace, and we'll see you next week on the Principled Podcast.

Outro; We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance in global organizations, by helping them foster winning, ethical cultures rooted in sustainable values. Please visit us at LRN.com to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcasts, or wherever you listen. And don't forget to leave us a review.

 

S7E15 | Why company values matter to an effective code of conduct

What you'll learn in this podcast episode

Over the last 20 years, codes of conduct have undergone an evolution. Originally written as textbook-sized rulebooks, codes now seek to be visually engaging, readable, and useful guides to employees to help them do the right thing. And rather than covering all manner of what you can and cannot do, today’s codes aim to illustrate values-based principles of what you should and should not do. But these changes are no small task. How can organizations ensure they are designing and implementing their codes to deliver effective and meaningful change? In this episode of LRN’s Principled Podcast, Senior E&C Advisor Jim Walton talks about code reinvention with Carmen Jandacek, the Director of Ethics and Total Rewards at Arizona Public Service (). Listen in as the two discuss how APS reinvented their code of conduct to better reflect their organization’s culture, values, and employee experiences.

 

Principled Podcast Show Notes

• [2:02] - Carmen shares about her career background and getting into the ethics and compliance
  space.
• [4:07] - What is Arizona Public Service (APS)?
• [5:20] - The key drivers which led APS to undertake reinventing their code of conduct.
• [7:40] - The process of updating APS’s existing code.
• [10:11] - How was the code rewrite accepted among stakeholders?
• [12:10] - How did the reworked code turn out in the end?
• [13:35] - Carmen’s advice for other ethics and compliance teams who are thinking about
  updating their own codes.

 

Featured Guest: Carmen Jandacek

Carmen has worked for Arizona Public Service (APS) since 1996 and is currently the Director of the Ethics Office, Total Rewards, Health Services, HR Operations & Technology.

Carmen is the Founder and President of the APS LGBT Alliance, an employee network group, a board director of the Better Business Bureau serving the Pacific Southwest, board member of one•n•ten a local nonprofit and a member on the Greater Phoenix Chamber of Commerce Diversity & Inclusion committee. Carmen has an undergraduate degree in management, and she earned her MBA from the University of Phoenix in 1999. 

Carmen is an avid health enthusiast and believes the key to leadership success is a healthy mind and body.  She has participated in many biking, running and triathlon races and is an Ironman Arizona finisher.

 

Featured Host: Jim Walton

Jim Walton is a member of LRN’s Ethics & Compliance Advisory Services Team – with over 25 years of professional experience in corporate, institutional and government settings, spanning the fields of ethics and compliance; environment, health and safety; and energy management.

Since 2002, Jim has been passionately dedicated to corporate ethics and compliance – designing, developing, implementing and enhancing constantly-evolving, comprehensive, best-in-class, global ethics and compliance programs. Jim has extensive experience in writing, producing and communicating codes of conduct and corporate policies; designing, managing and implementing ethics & compliance risk assessments; implementing anti-compliance and bribery initiatives; conducting third party due diligence reviews; and helping managers at all levels become better ethical leaders.

Jim is a Certified Compliance and Ethics Professional.

 

Principled Podcast Transcription

Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership, and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace changemakers.

Jim Walton: Over the last 20 years, codes of conduct have undergone an evolution. Originally written as textbook-sized rule books, codes now seek to be visually engaging, readable, and useful guides to employees to help them do the right thing. Codes have also shifted their organizational priorities. Rather than covering all manner of what you can and cannot do, today's codes aim to illustrate values-based principles of what you should and should not do. But these changes are no small task; How can organizations ensure they are designing and implementing their codes to deliver effective and meaningful change?

Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Jim Walton, Senior Ethics and Compliance Advisor at LRN. Today I'm joined by Carmen Jandacek, the Director of Ethics and Total Rewards at Arizona Public Service. We're going to be talking about how APS reinvented their code of conduct to better reflect their organization's culture, values, and employee experiences. Carmen has dedicated more than 26 years of her career to shaping the culture, ethics, and compliance at APS, and has real insight into how the company has evolved as a result of its new code of conduct. Carmen, thanks for joining us on the Principled Podcast.

Carmen Jandacek: Thanks. I'm just delighted to be here today.

Jim Walton: Wonderful. Just to start out, maybe you could tell us a little bit about yourself and how you came into the ethics and compliance field. I'm always fascinated at the journeys that we've all taken to get here.

Carmen Jandacek: Absolutely, and mine was absolutely not the traditional way of coming out of college and then going into an ethics and compliance career field. I came to work for APS in 1996, and I spent the first 15 years of my career there on the human resources team. At that point in time, I was really ready for a change. I spent really primarily my time in the space of total rewards, compensation and benefits, and I wanted to look at some other areas where I could expand my career also.

An opening came up in our ethics office, and I immediately fell in love with the work. In ethics, you have such an opportunity to not only reinforce and build ethical culture, but the ability to really be the voice of employees and the ethical coach for leaders. It's a really unique role that I have purview and sight to our entire organization, so I can identify trends or issues in one area of the organization and use that as a preventative opportunity and strategy to counsel and coach the rest of the organization. So from my perspective, ethics and compliance work is rich, it's never dull, and it's highly underrated. I think ethics and compliance organizations are the backstop to good governance at any organization.

Jim Walton: That's great. I couldn't agree more, and I think your unique background is really a wonderful add to the ethics and compliance community. It's always fascinating to me to see kind of the multifunctional, and the variety and diversity of backgrounds of ethics and compliance professionals, and it only adds to our effectiveness. So, thanks so much for that. I wondered if you could also just set the stage a little bit by giving us a little bit of background about Arizona Public Service, for those who might not know much about your company.

Carmen Jandacek: Sure. At APS, we are a subsidiary of Pinnacle West Capital Corporation. We have roughly 6,000 employees, and we serve 11 of the state's 15 counties. We're headquartered in Phoenix, but we are serving primarily the entire state of Arizona. In fact, more than 1.3 million homes and businesses are served by us, and we've made some very bold commitments. We're committed to providing a hundred percent clean, carbon-free electricity to customers by 2050, and we are well on our journey to doing so. We are 50% clean energy today. We also run Palo Verde Generating Station, the nation's largest clean energy producer that is west of Phoenix, and that's really the foundation of our future of carbon-free energy.

Jim Walton: Well, that's all very exciting. I know a big part of the commitments that APS is making were instrumental in wanting to rewrite and redesign your code of conduct, and we like to talk about reinventing a code of conduct. So, what were the key drivers that led you and the company to want to undertake this project?

Carmen Jandacek: Absolutely. It's been an interesting journey because I also was involved in rewriting the code that we had prior to this code rewrite. We were coming off of a code that was based on policy and procedure, that was framed in policy and procedure, and we had a couple key moments that really culminated in the work that we decided to do. First, we just went through a CEO change. In the CEO change, the CEO, Jeff Goldner, launched a significant culture change throughout the organization. So we wanted to make sure that all of what we were presenting in our code of ethical conduct embodied what that culture change was.

Part of the culture change was all about being customer-centric focus, and I fully believe that in order to really deliver on the customer experience, you have to deliver on the employee experience. So, providing frictionless delivery and service, and providing information in a way that is easy for our employees to utilize. So really what we were doing is, from a company perspective, building from the customer backwards to make sure they had a great experience, and I wanted to do the same thing from the code, making our employees with basically the customer of our product kind of front and center.

We also, as I just talked about, embarked on the bold new energy commitment to be a hundred percent clean by 2050, and that is really the backbone of the strong purpose that we have, and that needed to be really woven through all of the different documents and all of the different components of the code of ethical conduct. So all of that came together and culminated in us realizing that our current code was not going to help us bring those things to life, it was not going to allow us to bring and capture all of the change that was happening to us as an organization. So we knew that we couldn't just iterate what we had today, we had to completely reinvent that code to support these key initiatives and align with our cultural direction.

Jim Walton: Any of us that have gone through a code rewrite, update, reinvention, we know that it can be a daunting prospect. So I'm just wondering if you might be able to walk us through the process a little bit. So, now you've decided that you wanted to update the code. How did you actually go about it?

Carmen Jandacek: Daunting is pretty much an understatement, but very frankly, the LRN team made the complicated seem really easy for us. So we had to collaborate with over 30 different stakeholders and reviewers at APS, and it's never easy when you have that many editors, pulling all of those people together and capturing all of their comments to make sure that code was reflective of the important components that they had responsibility over. But all of the timing lined up. We had just deployed Microsoft Teams, and we created a Teams site, and had the reviewers put input in the one master document. And then I as the final editor either accepted or kept the comments that they had added.        

Interestingly enough, and I have done this now a number of times where I've had to have really large documents with multiple stakeholders, we did something different this time. I had one of my colleagues go through and for every comment we didn't accept, we wrote a narrative as to why and sent it back to that person. I have never received as many thank-yous as I did by saying, "Wow, that's pretty awesome. Thanks for letting me know why you didn't accept that." Many times I'd never hear, and I thought, "Boy, that's something I'm keeping in the back of my mind for any future endeavors that I have, in whatever space it might be that closing that communication loop is so critical for people there."

After we solidified the content component and we then moved to layout, (and the layout portion was, again, a partnership with our creative team and the LRN creative team,) our final stop on the journey after that was getting our board's approval of our content. And then we actually shared the code during our annual training deployment that we do, and now we're getting ready to do Ethics Reinforcement Week. So we are getting ready to deploy the actual leader training and conversation guide that we created as part of this, and are excited to have that reinforcement opportunity for our leaders and employees.

Jim Walton: Wow. That sounds fascinating. I'm curious with the subject matter experts and the internal stakeholders, was there a difference in some people understanding why you were maybe trying to make it less policy-focused and more simple? Was there a difference across the board how different people viewed that, and did it take a while to get some people to understand that?

Carmen Jandacek: Absolutely. I think it did, and I think that this is part of the evolution of just codes of ethics and compliance period across not just only the utility industry, but just period that is occurring. For many years, (and I can remember looking back at the first codes that we had, too,) it was a document that you might have needed to have a legal background to even understand. It was thick, it sat on the shelf, and it had all of the prescriptive language of the dos and the don'ts.

We really wanted to make this something that people could use in the flow of work that covered of course our compliance-related things, but didn't use that as the lead and really tried to make this a more conversational, understandable document that people wouldn't really fear picking it up, thinking that it would be complicated to navigate or to get the information that I was looking for. So when you look at the utility industry period, we're very compliance-based. So, it's small steps to get us to that place, but I think really all of my team and all of the stakeholders approached it with a really strong growth mindset, and we leaned into making some of those changes to create the great product that we have today.

Jim Walton: That's great. Yeah, I always say it takes a village to make a good code. So, it sounds like you pulled all the people together that you needed to. How did it come out? What are you most proud of when you look at your code?

Carmen Jandacek: There are so many different things. First of all, it possibly is one of the most beautiful codes that I've ever seen, literally. The visual components of it are striking, and that's all part of pulling you in. That is all part of pulling you into the user-friendliness of the document, is its appeal when you open that up. It's easy to navigate. We've got all kinds of built-in navigation. We utilize different modalities. So we've got videos that are in there, we've got other different links that we have built into the document. It's engaging.

So it's something that as we put it on our internal intranet site, it's very easy to pull up and get to your answer in literally one to two clicks versus having to scroll through a document before. So not only is the content really rich, it speaks of us. It really represents who we are as APS, our values. What we call our "APS promises" thread through the entire document. So it has just lifted all of the efforts that we are doing and pulling them together. A really good resource for our employees.

Jim Walton: Well, that's really good to hear. That's kind of the dream of what we want a code of conduct to do in this day and age. So I'm really glad to hear that. Finally, just to close it out, what advice do you have for other ethics and compliance teams who are thinking about updating their codes?

Carmen Jandacek: I think certainly what we look to achieve and we did is moving from a legal document to a guidebook for our employees and our leaders, and code from my perspective can be one of the most powerful tools an organization can have to throttle success in the decision-making space, and in laying out cultural expectations. When I think of it from the eye of the employee, really from the user's point of view, that's what I want them to walk away with. Our business is changing so rapidly that what we used to think was okay from a refresh perspective every five years, that seems like an eternity now.

So we have to be more willing to update, accept, and reflect the new ways of working and new work expectations. COVID certainly has changed that component of it, also. And I think what really made this the incredibly rewarding kind of experience that we had was the strong partnership that we had with your team, which makes really an overwhelming effort seem very achievable. And when you bring the experience that your team brought to the table, it really allows us to deliver strongly for our employees.

Jim Walton: Well, clearly this is a conversation we could be having for hours, but unfortunately we're out of time for today. Carmen, thank you so much for joining me on this episode.

Carmen Jandacek: Jim, thanks so much. It's been an absolute pleasure being here today.

Jim Walton: My name is Jim Walton, and I want to thank you all for listening to the Principled Podcast by LRN.

Outro: We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance in global organizations by helping them foster winning ethical cultures rooted in sustainable values. Please visit us at LRN.com to learn more. If you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcasts, or wherever you listen, and don't forget to leave us a review.