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Since 1993 we have emphasized strengthening ethical organizational cultures. This emphasis on a culture of integrity is based on the reality that no matter what kind of ethics or compliance program a company has, in the end culture wins. Famously, Enron had many of the elements of an effective compliance program as defined in the original U.S. Sentencing Guidelines for Organizations, but its culture shaped behaviors more than the written rules did.

Our role as consultants is to help organizations strengthen cultures of integrity by effectively implementing ethics and compliance programs. Implementing an effective ethics and compliance program is easier said than done. We have an excellent track record because we have a clear understanding of the possibilities and the dangers.



The word ethics means many things to many people. Especially outside the United States, ethics is equated with matters of personal morality. Ethics is perceived as outside the legitimate scope of management interest or interference.

Business ethics can also be perceived as soft, emphasizing “being nice” over business results.

Finally, scholars and practitioners of business ethics can emphasize values and virtues above all, forgetting that businesses are highly regulated and many laws and regulations require detailed knowledge and systems in order to comply.

Being a good person is simply not enough.



The very definition of compliance undermines the spirit of innovative capitalist enterprise. The first two entries in Webster’s Unabridged Dictionary for compliance are
  • The act of conforming, acquiescing or yielding; and
  • A tendency to yield readily to others, esp. in a weak and subservient way.
 Not exactly the characteristics most of us are looking for in a company, a leader, or even an employee.

As if this isn’t a big enough problem, practitioners of compliance often place great reliance on policies, procedures and auditing. They can forget that human beings have a great history of ignoring or circumventing rules.

Being an informed and audited person is simply not enough.



Ethics and compliance only have the power to be dangerous because they are powerful drivers of human and organizational behavior. Two examples from our work make this point clear.

Many years ago, a large multinational consumer products company asked us to do a baseline assessment of their ethics and compliance culture. In focus groups around the world, we talked to employees about what the company’s priorities were as they saw them. All over the world, we heard three priorities
  • Make Plan.
  • Make Plan.
  • Make Plan.
 Nothing else was even close.

The CEO was astounded. “When I tell people to make plan, of course I mean to make it in the right way.” We gently suggested he incorporate this nuance in his communications.

We also worked with the company to incorporate the “Make Plan means making it the right way” message into other communications and training. And over time, employees got the message. Now they will tell you that “Making Plan” is still the number one priority (certainly justifiable for a publicly traded company in the U.S.), but they do have other strong candidates for the other priorities. Concerns like quality, safety, and responsibility have made the list. Good implementation of an ethics and compliance program can shape a global culture.

Or a local one. Steve Priest was co-facilitating an ethics and compliance training session for managers in a geographically isolated business unit of a large utility company. After one of the sessions, a self-described “old-timer” asked Steve if he would like a little tour. At the end of the tour, the self-appointed tour guide turned to Steve and said, “Thank you for setting us free.” It turns out that this location had been managed by a tyrant for years. He was a trash talking, discriminating, retaliating terror. And after a few successful retaliations, people lucky enough to have a good job in this small town, decided to shut up and keep them.

Until one day, the Ethics Officer and a few other execs flew in to have a town hall meeting, with ethics and compliance as a primary theme. This old timer said that, “then and there I knew I would take the risk—the company seems like it is finally serious about this.” He called the Helpline. An investigation corroborated his allegations—and more. The tyrant was dismissed.

Effective ethics, compliance and corporate responsibility programs help organizations strengthen cultures of integrity. Ethical Leadership Group helps make those programs effective.