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Beyond Compliance™:
How to enhance ethical
management to support
the overall business
strategy?
1	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
Food quality?
Inventoryirregularities?
Corruption by/
of suppliers?
Anti Trust issues?
Correct reporting
on time as basis
for remuneration?
Price fixing?
Environmental issues? Dumping prices?
Health & safety at
the workplace?
Human rights?
Legality of working conditions?
What are your current compliance challenges?
Fraud
2	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
Corruption in the
value chain?
The standard compliance approach focuses on
the black sheep only
The standard compliance approach focuses on risk
mitigation through enforcement of rules and
regulations.
The basic assumption behind is, that bad things are
done by “bad people”. Scandals in corporations are
attributed to greedy managers with character
deficiencies.
Accordingly, the compliance systems in corporations
are designed to keep “bad people” in check.
3	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
…and forgets that good people do bad
things in bad contexts.
But from what have learned from recent scandals is
that persons with a high level of integrity who are put
into a pathological context will probably misbehave:
bad contexts can push good people towards illegal
and immoral decisions. This is nothing knew. This
phenomenon has been widely examined through
psychological experiments that scholars have
conducted in the early 1950s/1960s in order to
understand the mechanisms behind.
4	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
authority	
  low	
  trust	
  	
  
compe..ve	
  environment	
  
internal competition	

fear	

consensus driven culture	

tolerance of
wrongdoing	

performance	
  
pressure	
  group	
  
think
peer pressure 	

.me	
  pressure	
  
lack	
  of	
  role	
  models	
  
diffusion	
  of	
  responsibility	
  
rou0nes	
  
5	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
Challenges legalistic compliance ignores:
How we turn ethically blind?
We perceive the world through a filter
6	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
slippery slope of incremental change
time
Actual
situation:
(all potential
situational,
environmental
and
organizational
pressures and
stimuli)
Ethical
Blindness
Psychological
Factors
- values
- cognitive style
- personality
Observable
Experience
- education
- functional
background
- other factors
Limited
Field
of
Visioni	
  
Selective
Perception
Inter-
pretation
adapted from Finkelstein, S., Hambrick, D.C., Canella, A.A., 2009, Strategic Leadership, here: Bounded Rationality, p. 45
Risk
Time
(Reactive)(Proactive)
Financial & Reputational Damage
Integrity
Culture
What you manage:
Compliance
Culture
7	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
With the standard approach the rising tide
of integrity risks is noticed much too late.
Contexts are stronger than (most) people
We know that it is extremely difficult for everybody
to live up to our values when there is a “bad context”
around them.
It is not realistic to expect heroism from employees –
fighting “the system” on a daily basis. For an
organization to transform into the next level of
ethical conduct, the “context” itself has to be
addressed.
In an organization of black crows, the single moral
hero (white crow) has little impact.
8	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
Beyond Compliance™ or:
moving the organization towards an integrity culture
9	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
Beyond Compliance™:
Turning Compliance into a Partner!
•  The idea is to use the compliance approach (practices) and systems
to not only ensure high quality of products and processes but also
use it as a vehicle to support integrity, passion and excellence
through a behavioral change.
•  Behavioral change does not happen over night, it has to be initiated,
communicated, trained and rewarded. In order to be successful,
behavioral change needs to be part of the companies’ strategy.
•  We can support you in initiating, communicating and training of
behaviors, attitudes in order to promote ethical conduct and
integrity at the working place – beyond compliance.
10	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
integrity
check-up
•  Ethical blindness risk landscape and recommendations
Roll-out
•  Create awareness on ethical blindness and develop positive
peer pressure and value resillience
Embed and
sustain
•  track KPI’s, embed in management systems, anchor in
behaviours
11	
  www.palazzo-­‐palazzo.com	
  &	
  www.mylearningbou0que.com	
  
Our Beyond Compliance™ Portfolio
milestones
integrity
check-up
• interviews with top level management
• trigger points survey
• analysis of policies & procedures & strategy alignment
• Analysis of communication concept
Roll-out
• developing roadmap
• integrity training cascade
• communication alignment
Embed and
sustain
• KPI tracking
• third party involvement
• tailor-made training for selected key groups
• embedding integrity into HR policies
12	
  www.palazzo-­‐palazzo.com	
  &	
  www.mylearningbou0que.com	
  
Our Beyond Compliance™ Portfolio
actions
Get in touch to find out more:
13	
  (c)	
  www.mlb-­‐consul0ng.com	
  &	
  www.palazzo-­‐palazzo.com	
  	
  
Anna Eckardt, L.L.M.
phone: + 41 78 920 25 46
email: anna.eckardt@mlb-consulting.com
Bettina Palazzo, Ph. D
Phone: +41 79 697 56 28
email: bettina.palazzo@mlb-consulting.com

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Enhancing ethical management

  • 1. Beyond Compliance™: How to enhance ethical management to support the overall business strategy? 1  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com    
  • 2. Food quality? Inventoryirregularities? Corruption by/ of suppliers? Anti Trust issues? Correct reporting on time as basis for remuneration? Price fixing? Environmental issues? Dumping prices? Health & safety at the workplace? Human rights? Legality of working conditions? What are your current compliance challenges? Fraud 2  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com     Corruption in the value chain?
  • 3. The standard compliance approach focuses on the black sheep only The standard compliance approach focuses on risk mitigation through enforcement of rules and regulations. The basic assumption behind is, that bad things are done by “bad people”. Scandals in corporations are attributed to greedy managers with character deficiencies. Accordingly, the compliance systems in corporations are designed to keep “bad people” in check. 3  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com    
  • 4. …and forgets that good people do bad things in bad contexts. But from what have learned from recent scandals is that persons with a high level of integrity who are put into a pathological context will probably misbehave: bad contexts can push good people towards illegal and immoral decisions. This is nothing knew. This phenomenon has been widely examined through psychological experiments that scholars have conducted in the early 1950s/1960s in order to understand the mechanisms behind. 4  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com    
  • 5. authority  low  trust     compe..ve  environment   internal competition fear consensus driven culture tolerance of wrongdoing performance   pressure  group   think peer pressure .me  pressure   lack  of  role  models   diffusion  of  responsibility   rou0nes   5  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com     Challenges legalistic compliance ignores:
  • 6. How we turn ethically blind? We perceive the world through a filter 6  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com     slippery slope of incremental change time Actual situation: (all potential situational, environmental and organizational pressures and stimuli) Ethical Blindness Psychological Factors - values - cognitive style - personality Observable Experience - education - functional background - other factors Limited Field of Visioni   Selective Perception Inter- pretation adapted from Finkelstein, S., Hambrick, D.C., Canella, A.A., 2009, Strategic Leadership, here: Bounded Rationality, p. 45
  • 7. Risk Time (Reactive)(Proactive) Financial & Reputational Damage Integrity Culture What you manage: Compliance Culture 7  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com     With the standard approach the rising tide of integrity risks is noticed much too late.
  • 8. Contexts are stronger than (most) people We know that it is extremely difficult for everybody to live up to our values when there is a “bad context” around them. It is not realistic to expect heroism from employees – fighting “the system” on a daily basis. For an organization to transform into the next level of ethical conduct, the “context” itself has to be addressed. In an organization of black crows, the single moral hero (white crow) has little impact. 8  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com    
  • 9. Beyond Compliance™ or: moving the organization towards an integrity culture 9  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com    
  • 10. Beyond Compliance™: Turning Compliance into a Partner! •  The idea is to use the compliance approach (practices) and systems to not only ensure high quality of products and processes but also use it as a vehicle to support integrity, passion and excellence through a behavioral change. •  Behavioral change does not happen over night, it has to be initiated, communicated, trained and rewarded. In order to be successful, behavioral change needs to be part of the companies’ strategy. •  We can support you in initiating, communicating and training of behaviors, attitudes in order to promote ethical conduct and integrity at the working place – beyond compliance. 10  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com    
  • 11. integrity check-up •  Ethical blindness risk landscape and recommendations Roll-out •  Create awareness on ethical blindness and develop positive peer pressure and value resillience Embed and sustain •  track KPI’s, embed in management systems, anchor in behaviours 11  www.palazzo-­‐palazzo.com  &  www.mylearningbou0que.com   Our Beyond Compliance™ Portfolio milestones
  • 12. integrity check-up • interviews with top level management • trigger points survey • analysis of policies & procedures & strategy alignment • Analysis of communication concept Roll-out • developing roadmap • integrity training cascade • communication alignment Embed and sustain • KPI tracking • third party involvement • tailor-made training for selected key groups • embedding integrity into HR policies 12  www.palazzo-­‐palazzo.com  &  www.mylearningbou0que.com   Our Beyond Compliance™ Portfolio actions
  • 13. Get in touch to find out more: 13  (c)  www.mlb-­‐consul0ng.com  &  www.palazzo-­‐palazzo.com     Anna Eckardt, L.L.M. phone: + 41 78 920 25 46 email: anna.eckardt@mlb-consulting.com Bettina Palazzo, Ph. D Phone: +41 79 697 56 28 email: bettina.palazzo@mlb-consulting.com