Compliance professionals often ask me how they can better communicate with their front-line teams. I usually respond, “Bring them in, ask them about the real risks they face, and the more upset you are by what you hear, the better that conversation is going.”
Why? Because you can only fix what you know.
That was the topic of an article in the latest edition of the Harvard Business Review, Can Your Employees Really Speak Freely?
The authors, James Detert and Ethan Burris, identify two main reasons why employees don’t speak up: fear of consequences, and a sense of futility.
What about anonymous hotlines? Here the authors explode the conventional wisdom. “Allowing employees to remain unidentified actually underscores the risks of speaking up-and reinforces people’s fears.”
In other words, the message from an anonymous hotline is, “It’s not safe to share your views openly in this organization.”
As to the open doors in the C-suite we often read about, the authors found them “simply too passive.”
So how do we address “candor-inhibiting behavior” and getting beyond “pseudeoparticipation?” Here are a few recommendations from Detert and Burris about how to encourage those who face corruption risk to speak up:
Be specific: Bringing in your teams (or going to see them) and asking them to open up is unlikely to inspire dialog. Instead, “specify the kind of input you are seeking” and (my suggestion) share why — to help them manage corruption risk by calibrating compliance tools to the real-world risk they face.
Follow up: When the sessions are over, “synthesize the information and then take action.” Don’t add your meetings to the graveyard of rolling-eyes events where front-line teams feel their time was wasted on perfunctory summits with no result or follow-up. In other words, make sure you tell them what you are going to do next for follow-up, and what they can then expect as a result.
Cast a wide net: In addition to those in the field who have direct contact with corruption risk, consider others who might know something you don’t. Those employees could be deep down in your organization, working in credit and collections, sales order processing, and logistics. Processing an international order typically requires many hands, and you might be surprised what some members of your support teams see and hear.
Also, when onboarding new international team employees, ask them how the same compliance process was done in their previous position. Sometimes new employees are anxious to share how other organizations operate and will have a fresh perspective on your firm’s strengths and weaknesses.
Soften up: “If you want to get the truth from below, play down your power when interacting with employees.” I once worked for someone who was an officer in the U.S. Military. He shared with me that after a training exercise, he would bring in the unit for a “best-of, worst-of” session. He would tell his team to come in civilian clothing, as he wanted no visible signs of rank or privilege. What he wanted was open and honest dialog, even about his own leadership. Think about the strength of that message.
As Detert and Burris conclude in their HBR article, “Most people care too much about their social and material well being to routinely speak truth to power.”
So to clear the obstacles to real communication about risk and compliance, help people feel safe and believe that their time is well spent, no matter where they (and you) sit on the org chart.
Richard Bistrong is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLC. He was named one of Ethisphere’s 100 Most Influential in Business Ethics for 2015. He consults, writes and speaks about compliance issues. He can be contacted here.