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After that depressing news, let me cheer you up

I was planning a corporate event with the VP of ethics and compliance. He had a request. “Please finish your presentation on a positive note.” Point taken.

Talking about behavioral tipping points — bribing not to lose, bribing when the finish line is close, and even the impact of addiction upon corrupt behaviors — can all be discouraging and depressing.

Fortunately, Katharine Milkman and Theresa Kelly, cited in my finish line post, also have suggestions about how we can achieve better ethical decision making.

Structural incentives, for example, mean decision makers aren’t punished for inconsistency. In one of my first jobs my supervisor said, “Don’t feel compelled to follow a bad decision by a dumb decision.”  That’s good advice. A front-line manager should always operate in a culture that values abandoning an opportunity in lieu of unethical or illegal conduct. Better still, a manager should be rewarded for reversing course where continuation puts everyone at risk. That’s not inconsistency, that’s sound judgment.

A companion to incentives is to not consider expended resources when making decisions. Refraining from corrupt transactions should be devoid of sunken costs, and regional as well as line managers should feel empowered to cut the chord on potential corrupt conduct regardless of those costs. That sounds obvious to compliance personnel but it looks far more complicated and stressful from the front lines, especially during quarterly forecast calls.

Finally, in Milkman and Kelly’s words, “Make sure decision makers are frequently reminded of the goals of the investment.” In simple terms, the goal of trying to win above all else sends the wrong message. Business development goals should be framed around ethical and sustainable commerce that brings value to all parties, not just putting numbers on the board.

As Professor Francesca Gino has said, “The best way to maintain our high ethical standards is to keep them salient in our minds and to stick with them, especially in situations that we may perceive as tempting.”

In the field, especially in low integrity regions, adhering to high ethical standards can be like biking up hill. Complacency reverses our course, but steady and consistent focus keeps us on the right path upwards and onwards.


Richard Bistrong is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLC. He consults, writes and speaks about compliance issues. He can be reached via his website, twitter and email.

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