Ten Steps to Designing a Comprehensive Ethics Program

by Josephson Institute on December 6, 2010

1.  DIAGNOSIS & EVALUATION

  • Organizational Values – What do employees, especially mangers, perceive as the stated and operational values of the organization based on formal documents, formal and informal training, reward systems
  • Organizational Conduct – What is the perception about the congruence of stated and operational values and the prevalence or frequency of questionable, improper or illegal conduct?
  • Personal Values – What are the personal attitudes, opinions and beliefs of individuals, especially managers, and how compatible are these with the stated or operational values?
  • Personal Conduct – How consistent is the personal conduct of individuals within the organization, especially managers, with their own values and those of the organization?

2.  STRATEGY DEVELOPMENT

  • Goals for Change – What changes are desirable and necessary in the operational values and behavior of the organization and individuals?
  • Stakes – Clarify the stakes; what are the potential risks and rewards relating to the desired changes?
  • Commitment – How committed is the leadership of the organization to accomplishing these changes?
  • Time Frame – What is the time frame in which meaningful changes must be accomplished?
  • Resources – What resources, expertise, credibility, personal and financial are needed to accomplish the goals in the required time?

3.  STANDARDS OF CONDUCT

  • Draft and promulgate standards of conduct & policies
  • Articulate organizational values
  • Provide guidelines for dealing with potential value conflicts
  • Standards for specific functional contexts
  • Mechanisms for dealing with improper conduct

4.  RECRUITING & HIRING

Integrate value and behavioral goals into recruiting and hiring process so new employees are:

  • Disposed to honor those goals
  • Clear as to the expectations of the organization

5.  EDUCATION & TRAINING

Educate new and veteran employees about organizational values and standards of conduct, principled reasoning and ethical decision making to:

  • Provide an understanding of the nature and reasons for the organization’s values and rules
  • Provide an Opportunity to question and challenge values for sincerity/practicality
  • Teach ethical decision making skills related to commonly encountered issues
  • The more specific and customized the training, the more effective it is likely to be

6.  STAFF EVALUATION & PROMOTION

Integrate value and behavioral goals into:

  • Performance review process
  • Employee counseling
  • Promotion decisions

7.  SUPPORT SYSTEMS

  • Mechanisms for allowing employees to get additional instruction, clarification and guidance on how to deal with issues concerning organizational values and standards of conduct

8.  DISSENT/FEEDBACK CHANNELS

  • Process for reporting misconduct without fear of retaliation
  • Information learned through complaints and investigations should be fed back to managers and integrated into annual training programs and follow-up audits

9.  AUDITING & MEASUREMENT

  • Establish ongoing mechanism audit actual behaviors adherence to values
  • Isolate cases that require action or discipline
  • Deter improper conduct by creating likelihood that it will be discovered and appropriately sanctioned

10. COMMUNICATIONS REINFORCEMENT

  • Various methods of organizational communications should reinforce both commitment to ethical principles and the core values of the organization

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