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The case for ethics-based communication across the c-suite

Expert panel discussion at the NYSE. Photo by Ben Hider.A workshop at the New York Stock Exchange has explored ways for the c-suite to participate in the corporate-based dialogue on compliance.

An FCPA Blog post highlighted last month that audit, legal and risk professionals are needed to frame corporate communications to express the business’ ethics program and culture. That communication function is growing to include the whole c-suite, said panelists at the October 24 workshop on “Best Practices in Ethics Communications” hosted by Ethisphere Institute and coordinated by Ethisphere’s Communications Advisory Board.

“Ethics is how you should act and what you should do. It means going beyond legal requirements,” said Paul Argenti, professor of Corporate Communications and Corporate Responsibility at the Tuck School of Business at Dartmouth University. “After all, trust gives us our license to operate. It is based on the notion that employees and companies will always provide collective trust.”

The responsibility for building trust within our respective organizations — for our customers and clients — lies with us,” said Paul Gennaro, AECOM Technology Corporation’s senior vice president and chief communications officer who also chairs Ethisphere’s Communications Advisory Board.

In the wake of so many corporate failures and government enforcement actions, compliance is taking on a new dimension that truly embraces the notion of “tone at the top.” In an effort to ensure that ethical codes are enforced, corporate compliance professionals are starting to include mechanisms for effective communication that emanate from top executives to employees, vendors, investors and the public.

“Setting the appropriate tone for a culture of compliance centers on communication about the importance of compliance to the organization and the conduct expected of all employees, including the executive officers, agents and directors,” said Holly Gregory, a partner at Weil Gotshal Manges.

She addressed communication relating to FCPA compliance, saying it must serve as a means for these persons to report their concerns about FCPA violations and other compliance risks.

According to Gregory, there are several ways to communicate your FCPA message across a company’s operations, including:

  • Ensure the FCPA policy is clearly written and includes examples that are tailored to your business and business-related risks of compliance failures
  • Encourage corporate leaders to discuss regularly the importance of compliance in their communications with employees and agents
  • Tweak communications and education programs to the audience with consideration paid to the level of FCPA risk posed by the particular employee’s (or agent’s) function, and
  • Refresh the understanding of employees and agents about their FCPA obligations, making sure that such annual (or more frequent) efforts do not become a rote exercise

In the end, good communication not only helps establish tone and expectations, but it also provides a means to identify areas of potential vulnerability, Gregory said.


Aarti Maharaj is a Senior Writer in AECOM’s Corporate Communications Department and a freelance reporter on corporate governance, compliance and ethics.

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