I worked during four years in Telia Company as Chief Ethics and Compliance Officer, leading the Ethics and Compliance (E&C) work up to the DPA in September 2017.
I was brought onboard in 2013 to ensure change, restore trust and to establish an E&C function with a credible anti-bribery corruption program as the company was going through a reputational, legal and ethical crisis with allegations of corruption in its business in Uzbekistan.
We set up the E&C function, introduced a whistleblower solution and a special investigations office, and carried out investigations throughout the business region Eurasia. We introduced a remedial action plan, trained over 5,000 employees in f2f workshops, initiated and lead several projects for third parties including a new due diligence team, terminated contracts and tracked payments.
A new board and new top management replaced leaders and employees on global, regional and local levels, implemented new governance models and new committees for governance, risk, ethics and compliance.
Compliance, Conduct, Culture. Yet, after two years of work, I felt discouraged, exhausted and worried. The good work seemed to cause overwhelming internal disagreements, arguments and difficult conversations.
Anna, my deputy and anti-bribery compliance program lead, and I spent some late evenings discussing why it was not working. Being fundamentally optimistic, we then realized that the exhaustion and friction was a sign of change.
In the ethics & compliance profession, there is a lively debate on rules or culture, compliance or ethics. But I phrase this as “rules and culture, ethics and compliance.” I believe that compliance cannot work without ethics, and ethics cannot work without compliance.
Still, Anna and I realized that implementing effective compliance generated friction and revealed dilemmas that previously had been possible to avoid or ignore.
How a company handles the friction and the dilemmas generated from effective compliance work, how it conducts itself, will create the culture in the company.
We often talk about the importance of culture but it will not build itself, nor through statements of culture. You build culture through repeated conduct.
The possibility, capability and courage to choose. In exposing the different, sometimes conflicting, interests in alternative solutions to a dilemma, compliance work gives the leaders a possibility to choose.
Terminate the agent or close the deal? Focus on quarterly or long term results — on shareholders or significant stakeholders? Be transparent, or not? Do what you can get away with or what is right?
How do we in E&C manage the friction generated and how do we support leadership “doing the right thing”? I believe we should support leadership by giving them an opportunity to practice being in the fray and friction, showing them that a dilemma is rarely black or white but a zone of grey, where you must choose.
By building an awareness of corporate responsibility, and that diversity and inclusion result in better decisions, and that even the best people can become ethically blind under certain circumstances and situations. Enabling leaders to develop a capacity to choose.
As E&C professionals, we’re used of working with fear. Fear of prosecutors, fear of going to jail, fear of failing the shareholders, fear of journalists and reputational damage. Fear does not promote a capable and courageous leadership. Fear does not build ethical business culture.
We have to find other ways to encourage and support leaders to be courageous.
Raising awareness that corruption is a matter of human rights may work better as incentive for leaders to do what they do best, lead, and to build stronger companies and businesses.
Michaela Ahlberg, pictured above, is an ethics & compliance specialist, lecturer and consultant supporting organizations and leaders with compliance and ethics, enabling cultural change. She can be contacted here.