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Harry Cassin
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Richard Bistrong
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Eric Carlson
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Richard Bistrong: When we’re squeezed, do ethical decisions flow out?

When I started blogging in 2014, there was little discussion about how issues like financial pressures and “micro-cultures” could impact decision making that can lead us astray.

Now, though, the OECD has published an engaging work, Behavioral Insights for Public Integrity, Harnessing the Human Factor to Counter Corruption, focusing on the interaction between policy making and integrity.

Even with the public-sector focus, the OECD paper serves as useful guide to compliance leaders.

“Integrity is more than a rational choice against corruption,” the report says. That’s why it’s essential to have ethics and integrity policies developed with a deeper understanding of what drives people to make an ethical decision if and when the moment of conflict arises.

The OECD advances the often overlooked “moral reflection” that goes into decision making, and how “social dynamics affect individual behavior.”  It looks at the influences and forces that can come between our actual behavior and our desired behavior. 

Also examined is how “ethical choices are not made in isolation, but as part of social interaction,” and that in our pursuit of top-line growth and commercial objectives, our values can get challenged. 

Where we work and live can also create significant ethical and compliance challenges.  

For example, Singapore is known as a law-abiding society. But Singapore’s Keppel Offshore & Marine Ltd. paid a total penalty of more than $422 million to resolve corruption charges with authorities in the United States, Brazil, and Singapore. After that enforcement action, I heard someone in Singapore ask: “Are business leaders changing their ethical hats when flying to their commercial destinations?”

We’re all subject to a wheel of biases. Yet, how can we help to mitigate these influences and pressures that can lead commercial teams astray if we don’t know what they are?

For starters, compliance policies should appeal to the human desire to behave ethically, to be a positive part of society. It’s about the why of compliance, and when sharing that dynamic, the goal is to trigger awareness and sensitivity as to the ethical implications of our decisions, by making it factual instead of theoretical.

As Max Bazerman and Ann Tenbrunsel said in Blindspots, compliance programs devoid of that ethical component can “contort the decision-making process” instead of enhancing it. 

The OECD report says “behavioral sciences can provide inspiration for innovative, modern integrity policies that harness the human factor in the fight against corruption.” If the goal, then, is to create an ethical moat around an organization, a good place to start is to create for each employee a pool of ethics and integrity where values, processes and policies make good sense to the task at hand and society at large.


Richard Bistrong, pictured above, is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLCIn 2010 he pleaded guilty to a conspiracy to violate the FCPA and served fourteen and a half months at a U.S. federal prison camp. He was named to Compliance Week’s list of Top Minds in 2017 and was one of Ethisphere’s 100 Most Influential in Business Ethics in 2015. He was named by Thomson Reuters in 2018 as a Top 50 Social Influencer in Risk, Compliance and RegTech.

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1 Comment

  1. Richard, great article, thanks! The one ingredient that many people who get caught up in this don't seem to possess, or care about, is the injustice that their actions cause to others. Their pendulum seems to swing based on whether they think they can get away with it. One of my old bosses at IRS-Criminal Investigation had a great line about ethics, i.e. "You never really know if you have ethics, until it costs you something".

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