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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
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Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Richard Bistrong: Can we teach ‘normal’ employees not to cheat?

The FCPA Blog recently asked, Why do normal employees violate the FCPA? As a sales executive who formerly considered himself to be one of those “normal” employees, that’s a question I’ve struggled to answer.

After I was hired as the VP of U.S. sales and marketing by my former employer in 1994, I helped to grow a robust network of domestic distributors and sales representatives. I supported the marketing department and even served on the company’s executive committee for a time.

During those initial years of 1994 through 1998, corruption wasn’t one of the headwinds I had to confront.

Yet 13 years later, my exhilarating start had produced a starkly different ending, culminating in my serving about 14 months in federal prison for bribery. So I know how employees can start off their career or a new role with nothing but good intentions, but fail to keep it that way.

The question, then, is how do we keep those “normal” employees from going so far off course?

From my own experience, both before my indictment and in my work now, I know about the constant struggle in organizations to balance professed values with practiced values. That conflict often hits hardest those employees who work in high-risk regions, where local practices might be inconsistent with corporate rules, leaving front-line teams to ponder what management really wants as they work toward their commercial goals.

In that environment, “normal” employees who face ethical dilemmas are often many time zones away from headquarters, and thinly supervised. It’s a situation full of peril. Typically those forward-based employees look for behavioral or organizational cues in their immediate environment instead of communicating with leaders back home who are tasked with keeping them successful and safe.  

That’s one of the great points Alison Taylor makes in her Harvard Business Review article, “5 Signs Your Organization Might Be Headed for an Ethics Scandal.” She describes people working in isolation who are “far more influenced by their immediate surroundings than by a code of conduct set at the top.”

Going further, it’s clear that the category of so-called “normal” employees isn’t static. We forget how competitive, complex and volatile markets can impact “normal” employees by creating uncertainty and tension, where the pressure to succeed (and keep one’s job) can outweigh and overwhelm the pressure to comply.

None of what I’m saying is an excuse for misconduct, including my own. But it is a call for us to remember those “normal” employees and what can happen when we put them under extreme pressures to be successful, while isolating them from the mother ship’s mangement and its compliance department.

So what should we do? I think we should proactively sensitize employees to what might happen in their work. That happens by increasing their awareness of the risks they’ll likely face, before they actually face them. And that requires some very deep discussions about what the organization wants to happen at the front lines of its business and what employees will likely encounter in their commitment to commercial success — in other words, what’s actually happening out there.

You can’t have those discussions if you’re relying solely on manuals or e-mail signatures. Those deep discussions start with personalized training. There also need to be clear messages from leaders that no one has to go it alone, and that it’s “normal” to be competent and confused when we’re trying to meet business goals in challenging markets, where opportunity and risk are intertwined.

If we know that “normal” people might become confused when we give them challenging targets to meet in volatile markets, why not teach them how to face that complexity before it happens, while they’re still in a safe zone?


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.

His popular real-life compliance training video, Behind the Bribe, produced in cooperation with Mastercard, was released in 2017. To request a demo of the full eleven-minute video or a licensing fee schedule, please click here.

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1 Comment

  1. Richard, your guidance that "clear messages from leaders that no one has to go it alone" is a key lesson that is often not shared or heard by the "normal" people on the front line. Thanks for sharing your insights and guidance as it is important to continue to learn what makes a difference.

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