Leading an Effective Ethics & Compliance Ambassadors Program

Extend the reach of your compliance and ethics program

Whether you call yours an “Ambassadors Program”, “Champions Program”, or “Liaison Program”, they all do the same thing—spread awareness and broaden the reach of your compliance and ethics program by using businesspeople as extra arms, legs, and ears.

Join us on 14 October 2021 for this one-day virtual conference, Leading An Effective Ethics & Compliance Ambassadors Program. Through sessions led by industry leaders, you’ll examine different state-of-the-art ambassador programs and ways to improve (or even launch) your own program.

Hot topics

  • Successfully navigating the changing landscape for ambassador programs
  • Optimizing the structure of your program to maximize effectiveness
  • Recruiting and training your ambassadors: It’s all about the people
  • Inspiring, sustaining, and expanding the network in the medium and long term and building in continuous improvement
  • Communicating with the wider workforce
  • Metrics and assessing your program’s effectiveness

Who should attend?

Compliance and ethics professionals

How do I sign up?

Right here: corporatecompliance.org/2021ComplianceAmbassadorProgram

Westminster eForum: Policy priorities for supporting emerging technology

Matt Hervey and I are on a panel at an upcoming Westminster eForum this November – and it’ll be a wide-ranging discussion – the full title for the exchange is:

Legal, policy, security, and regulatory priorities – supporting innovation while understanding risks, regulatory agility, IP, and strategies for effective knowledge sharing across sectors

Matt is head of Artificial Intelligence Law at Gowling (and topical with the volume The Law of Artificial Intelligence, co-authored with Matthew Lavy). My focus will be on Ethical Business Practice and Regulation (as you might have expected).

There’s lots more to look forward to on the day though – including the following confirmed speakers:

Emerging technology and the shifting landscape for regulation

With Gary Clemo, Director, Data Innovation, Ofcom

Supporting adoption – communicating the practical impact of emerging technology on solving real world challenges for organisations of all scales, and priorities for skills development and promoting career paths

With Sue Daley, Director, Tech and Innovation, techUK alongside

Priorities for research and development, and tackling barriers to cross-sector collaboration

With Dr Peter Waggett, Director, Hartree National Centre for Digital Innovation, IBM

Supporting innovation, facilitating investment in emerging technologies, and engagement across the public and private sectors

Robert Franks, Managing Director, West Midlands 5G

Policy priorities and the way forward for cross-sector standardisation and promoting the UK’s role as a global leader in the development and use of emerging tech

With Dr Scott Steedman, Director-General, Standards, British Standards Institution

Chair’s and Westminster eForum closing remarks

With Michael Ryan, Deputy Editor, Westminster eForum

I hope to see you there. And stay tuned to the programme as it develops:

westminsterforumprojects.co.uk/conference/Emerging-Tech-21

Photo credit: Houses of Parliament by Ugur Akdemir /via Unsplash

Culture & Conduct Deep Dive Report

The report from the 1LoD Deep Dive on Culture & Conduct is now available. Download the full report to get insights on the topic from a range of international experts. And here’s a quick preview of my comments on the risk of seeing culture as a cost:

“Leaders have a big role in creating the culture but they’re operating both from their individual mindset and their institutional mindset and they are influenced by the systemic context. For leadership to truly drive positive cultural change they need to understand and accept the business case for why culture work is important and that it produces better financial results. A lot of people don’t see it that way.”

Culture & Conduct is back on the agenda at XLoD Global 16-18 November 2021. Learn more (and book) here: 1lod.com/xlod

Here’s a speedy preview of the report – and you can flick through the whole report (and download it) here.

Thanks to 1LoD for compiling and sharing it – and hope to see you at XLoD Global!

Ethical Business Practice Capacity Building Commitment

SDG 16 : Peace, Justice and Strong Institutions

At AretéWork we are primarily committed to SDGs 16 and 17 (and within that sub-targets 16.5, 16.6. 16.7 – and 17.17 which, for us, tie them all together).

We encourage, promote and contribute to effective public, public-private and civil society partnerships.

Building on the experience from our work with OECD, UNODC E4J and other global and national initiatives we commit to giving 10% of our time yearly, pro bono, to non-profit endeavours focused on capacity building around Ethical Business Practice and Ethical Business Regulation. 

And in line with our Core Values of Making a Difference + Continuous Learning and Openness – we’ve filed the above commitment with the Council for Inclusive Capitalism. This is alongside many of the global actors we are working to help adopt Ethical Business Practice.

Learn more about the Council for Inclusive Capitalism

The latest issue of AretéWork is out…

We’re mixing things up and moving the AretéWork Quarterly to a new shorter format which will instead arrive a little bit more often.

I hope you’ll want to follow along – and share with others who might benefit.

In this new issue you’ll find:

The latest from AretéWork – Including a new book I’ve contributed a chapter to – use the AUDIT20 to get 20% off from the publisher.

A Q&A Chris Campbell and David Barr – which is one of a new series of Q&As with leading thinkers in the field.

Interesting ethics links from elsewhere – Because sharing is caring … and if you have something you’d like included in a future issue, let me know.

What we’re reading – A quick summer round-up. Got recommendations to add? Be sure to send them along…All the best to you and yours. Let’s advance #EthicalBusinessPractice together.

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‘there is generally in my experience far more corruption in countries with very rigid rules and very limited discretion…’

A brief AretéThoughts Q&A with Florentin Blanc:

What is the most important thing that regulators must learn from the pandemic?

Outcomes are what matters, not processes. And to achieve outcomes, you need to keep focusing on assessing, understanding, detecting risks. You need flexibility, and data. But this a lesson even more for those who make the rules “above” regulators, which often constrain the latter rather than empower them.

Are there ways to achieve a suitable degree of regulatory discretion without increasing corruption risk? Why would this be helpful?

The short answer is: yes. Why would it be helpful, first? Because optimal rules don’t exist: rules cannot predict everything. If you make them too rigid and precise and narrow, you will end up with bureaucracy, and inability to adapt and respond to events.

If you make them too loose, they will be useless. You need discretion, definitely.

How to limit corruption? First, regulators need to adopt and publish clear guidelines on how they exercise discretion, so that there can be accountability and review. Second, there needs to be transparency, and results management, accountability for results. Third, of course, properly professional regulators, with careers that attract good people, ethical internal structures and management. This is vital.

Finally, there is generally in my experience far more corruption in countries with very rigid rules and very limited discretion…

What is your current favourite book or podcast and why?

I don’t listen to podcasts, only music. Bookwise, I enjoyed a lot the “Interdependency” series by John Scalzi and the “Lady Astronaut” series by Mary Robinette Kowal, of which I read the last volumes a couple months ago – I find science fiction always both refreshes my brain through evasion, and has very interesting insights into society, technology, economics etc. Apart from this, I am an avid Twitter user – this is where I learn stuff, for instance the “airborne Covid” stuff which right now is my most exciting area of work and leads to the question of whether and how we could have a new regulatory “field”, (indoor) air safety.

Will the pandemic speed up the pace of regulatory change in some countries and what will drive the change, if you feel it will happen?

Maybe! I sure hope so. Particularly, I wish it would help regulators and most importantly politicians who make the laws that regulators work within to realize the importance of understanding and managing risks, rather than focusing on what is easy to control and measure. If change does not happen, we will continue to flail around with regulatory measures that deliver no results but have significant costs.

Florentin Blanc is a Senior Policy Analyst at OECD.

Read more AretéThoughts Q&As

Summer reading list

What am I reading at the moment? Well, quite a few different things.

I am almost finished with the Fearless Organization by Amy C. Edmondson. I was particularly struck by her description of the different responses and outcomes between Fukushima Daiichi and Fukushima Daini in the earthquake and tsunami of 2011. Fukushima Daini was led by Naohiro Masuda, plant superintendent, who inspired life-saving teamwork from his 400 colleagues through honesty, vulnerability, communication and information sharing. And, Professor Edmondson explains how he did all this with a whiteboard. It is a gripping story, and worth the price of the book alone.

I have started Michele’s Wucker’s new book, You Are What You Risk: The New Art and Science of Navigating an Uncertain World, after listening to her talk to Christian Hunt on the Human Risk Podcast. If any of you are procrastinating about mitigating risks in your personal life, this is probably for you.

Another personally motivated choice is Nir Eyal’s Indistracable. Having coped with a short attention span all my life; I am finding that the pandemic has reduced it further, mainly as a result of spending so much time at home. I used to scroll mindlessly through social media while on the Underground or while travelling so it didn’t feel quite as much of a problem – when I arrived at my destination, I stopped. Now there is no destination. As he points out you can only be distracted from something – and he urges us to explore the root cause for example, asking ourselves, what am I trying to avoid. Needless to say, this type of introspection can be painful!

On the plus side, I’m reading the other contributions to Roger Miles’ new book (mine is Chapter 13 on cultural measurement). The title of the whole book is Culture Audit in Financial Services.

And I’m reading Noise by Kahneman, Sunstein and Sibony after listening to three different podcasts featuring one or all of the authors. They must be exhausted!

I finished Rutger Bregman’s delightful book Humankind, A Hopeful History, and would recommend it to anyone who listens to the news daily.

What are you reading? Let me know on LinkedIn or @ruthsteinholtz.

OUT NOW: Culture Audit in Financial Services

In the next wave of conduct regulation in financial markets, from 2021 conduct regulators in the UK and elsewhere expect firms to produce evidence on how they are improving behaviour and culture. Facing this, many practitioners are anxious that their current reporting and management information (MI) are irrelevant to meeting as-yet unclear regulatory expectations.

This book provides the insights and tools firms need to report on culture, securing both enhanced business value and the regulator’s approval. Culture is now seen as a key contributor to good governance, feeding into existing discourse on environmental, social and governance (ESG) factors and the emerging dialogue on ‘non-financial (mis)conduct’, but conventional measures of business quality are unfit for the new reporting agenda. Culture Audit in Financial Services follows the arc of ‘behavioural regulation’ to examine what the regulator really wants, before offering guidance on how culture audit differs from conventional auditing, how to put the latest pure-research findings to work, and the key features of well-designed conduct and culture reports.

Written by an impartial author and a variety of contributors (including yours truly) with extensive experience working with practitioners, regulators, and many of the world’s finest academic initiatives, this book is filled with practical, grounded advice on how best to approach this new challenge and avoid infractions.

Get your copy today.

Proceedings: 13th Conference on Good Regulatory Practices

In case you missed, the proceedings from the APEC 13th Conference on Good Regulatory Practices are now available:

13th Conference on Good Regulatory Practices (GRP13)
13th Conference on Good Regulatory Practices (GRP13)

Emerging technologies have been and will be impacting all areas of social and economic activities, including transportation, education, finance, and health care.  While offering great promise, they also present unique challenges for regulators to strike a balance between promoting productivity and innovation, and maintaining health, safety, and environmental protections.  The GRP13 conference was held virtually to exchange notes among members and learn from the experts on their vast experience, lessons learned and best practices in improving mutual understanding about how regulatory policy itself is affected by the digital economy and in turn, how policymakers can improve regulatory system, making it agile to enable technological innovation. 

This report summarizes the experts’ sharing on regulatory design, delivery and reform with regards to new and emerging technologies, as well as touching on the relevance of the topics to the current crisis of COVID-19.  Performance-based regulations, regulatory sandboxes, international standards and international regulatory cooperation (IRC) were among the key points highlighted in the conference. Two of the key outcomes include the importance of private-public sector collaboration and further deliberation of the IRC.

Download the full report

Thanks to Srikanth Mangalam from the Public Risk Management Institute for introducing #EthicalBusinessRegulation to the proceedings. You can read an earlier Q&A with Srikanth here.

‘…be wary of sweeping generalisations of “the top 5 things to transform your training impact”’

A brief AretéThoughts Q&A with Chris Campbell & David Barr:

So David, you and Chris have just written the IBE’s latest Good Practice Guide – Trends and innovations in effective ethics education, what are your key takeaways:

Hmmm, I fear that’s hard to answer succinctly, or at least for me! It stems from what we heard clearly from all the ethics & compliance (E&C) heads we were fortunate to speak with. Which is: every company’s E&C programme has its own unique context – driving their risk profile, attitudes, resources and knowledge regarding E&C. All of which fundamentally impact what training actions (in the next 12 to 24 months at least) will have the greatest impact.

So, our first key takeaway: be wary of sweeping generalisations of “the top 5 things to transform your training impact” or “follow these key best practices for better performance”. But with that caveat in mind, if you step back far enough there were three key trends that in some way everyone we spoke with was grappling with.

Firstly, an increasing necessity to break down training and communication silos; and to co-ordinate, plan and co-develop training in a much more aligned way with other key corporate functions. Most notably HR and Health & Safety, but depending on context almost any function. This is simply necessitated by employee overload and ethics & compliance needing to impact behaviours and capabilities and not just knowledge and awareness.

Then, very closely linked with this is strengthening the focus on having the learner at the heart of your training strategy. We know this sounds almost too simplistic, but the E&C leaders we spoke with are being increasingly candid with themselves about how this core principle gets knocked off course. To their credit.

Then finally, and again these are all closely entwined, building out more informal and on-the-job training interventions, and not only relying on formal training, be it eLearning or live sessions.

Chris we heard a lot about putting the learner at the centre of your ethics training; how exactly can that be achieved?

For me, this is the big one and most ethics & compliance teams get it and start with the right intentions but through the process this becomes gradually lost or significantly compromised. It comes back to:

  • How does this benefit the individual and the organisation?  
  • Am I being efficient with their time and respectful of their knowledge and experience?

Using some form of profiling or test really helps, so that the content delivered (irrespective of medium) is relevant and can be applied. Use the technology for what its good at – targeting key information to the right person at the right time. Use the time you have face to face (real or virtual) to have purposeful conversations that allow a learner to really share their challenges and frustrations.

Being ‘learner centric’ means putting the learner at the heart of the training and considering everything through their eyes. How will a learner experience the education, how does the process of learning make them feel and what do we expect them to do differently as a result? Though I would stress it shouldn’t be read as simply “learner easy”. Training must still stretch and challenge; and it can still be demanding. 

David, can you share a short example of this?

There are many, but one we’ve been closely involved with and that’s having significant impact is the Responsible Business Discussion programme that Cedric Dubar and his team at Volvo Cars are leading. It stemmed originally from their Integrity Champions network being equipped with a suite of short discussion guides that they could draw from and use at local briefings or leadership meetings etc. These proved very popular with both the Champions and their colleagues. So with that foundation Cedric and the team pushed to receive backing from the Executive Committee to have nearly 4,000 managers run a Responsible Business Discussion every quarter with their teams.  Each discussion requires about 20 – 25 minutes of preparation time and supports an informal, but purposeful, ethics & compliance orientated discussion to be facilitated by a team member (normally the manager, but it doesn’t have to be). Each discussion focuses on a straightforward, but compelling case study or thought piece and will close with the team agreeing some specific takeaways that they can action.

For us this is learner centric, as it’s a team led discussion so immediately close and contextualised for the team, it results in the team agreeing their own actions, as team based there’s minimal disruption, and as 20 – 25 minutes once a quarter, minimal time. But across Volvo Cars they now have nearly 35,000 colleagues having a quarterly ethics & compliance discussion, led by a close colleague, where they develop and agree the actions. That’s remarkably powerful, and for us, very learner centric.

How do you think the pandemic has shaped the delivery of ethics training and are those changes here to stay?

I think we have all rapidly accelerated our capabilities and comfort with virtual sessions. Virtual delivery used to be wrapped in complex set-up instructions, guidance on backdrops and how to be “professional” when online. For the most that is gone, many people don’t want the corporate backdrop and like the brief window into each other’s lives. I think virtually delivered content will be a bigger part of the delivery mix, I think it will eat into eLearning as well as live physical sessions. And with regard to live sessions as Joni Mitchell said “you don’t know what you’ve got till it’s gone.” There is a greater respect for the value in being face to face and having a focused session that allows you to really dig into issues.

David, I know you are a big on your Podcasts, what would you recommend that those of us in the ethics & compliance world listen to:

It would have to be Tim Harford’s More or Less on BBC Sounds. It digs into numbers and statistics quoted in the media and encourages a questioning, but overall positive mindset. I’m a huge believer in being comfortable to question and kindly interrogate what is presented as fact!

And from you Chris what about a book?

The Tyranny of Merit by Michael Sandel. Sandel has been described as the greatest living philosopher, I have always found his writing to be entertaining and accessible. This book forced me to challenge some uncomfortable truths about my attitude to meritocracy. Thoroughly recommended!

Chris Campbell & David Barr are the co-founders of Campbell Barr.