Webinar: How to Promote Your Ethics Hotline

Transcript for How to Promote Your Ethics Hotline

Nick Gallo: Thank you so much for joining us. We have an awesome webinar today on a topic that I think is super interesting. There’s so much behavioral psychology involved and so many little tips that you’re going to be able to implement immediately to get things improved. So, welcome. Please, we want this to be as interactive as possible. So, if you have questions, put those in the chatbox, we’ll pass those over so we can get those answered. And these really are best when we can have a nice interaction with all the people who are attending. We’re going to circle back at the end of this with replays. We’ll send those out and we’ll also be sending out the SHRM credits. So, and the last thing is you got to stick around to the end because we got some real goodies for everybody who’s willing to stay to the end. So, Gio, take it away.

Giovanni Gallo: Yeah, sure. I’m super excited to introduce and feature Penny Milner-Smyth of Ethicalways. Penny is a really thoughtful and engaging speaker so get ready for some great ideas today. Throughout her career, she’s been an in house human resources leader. She’s had a decades-long specialization in the creation of ethical workplace environments, and she brings a really interesting and insightful academic background in neuro-psychology which you’re going to hear, you know, all of that greatness presented today in the things that Penny’s taking us through around how to actually properly promote your hotline and your reporting avenues. Penny, welcome to the webinar. Thanks for joining us.

Penny Milner-Smyth: Wonderful. Thank you so much for inviting me, Gio and Nick, and great to have so many people joining the webinar. So, if we handing over, welcome. If some of my pronunciation and spelling on the slide seem strange, it’s because I’m speaking to you from South Africa where we follow the English United Kingdom conventions, and it’s not that I can’t spell, it’s just that we spell differently. So, apologies for that, but I hope to be bringing you from the tip of Africa global insights that are as relevant in the U.S. and wherever it is that you’re making contact with us from, and especially those that are relevant for the people you need to reach wherever they are in the world. So, while it might be that often we have a predominance of employees that we’re wanting to reach closer to our head office operations, it can be that the people we most need to reach are those people in remote locations, in small groups, and especially in organizations that get just a little bit big that we don’t have line of sight. And that is where the hotline is so exceptionally important.

I’m going to try and go with some less traditional input today. I’m going to do it pretty fast. So, please put your seatbelt on while I try to cover a lot of ground in order that we can conclude with some very clear recommendations for you on the promotion of your hotline. But I really hope that you had a pen and paper ready because what I’m going to be doing is introducing you to different areas of thoughts or different concepts that you can quickly run with in developing solutions that work for your organization, applying that concept. I’m not always going to be giving you the solution, but I’m going to be sharing some really important and valuable content, and I’ll hope from disciplines that you’ll be quite keen to go and learn more about going forward.

What I should say is that while everything I’m talking about today is evidence-based, it’s also based on applied experience. So, while today I do a lot of work on creating a speak-up culture and my elevating integrity program is something that I run for a wide range of organizations around the world. One of the things that I spend a lot of time looking at is how best we can encourage people to find their voice at work. And that’s not just because essentially my work is about avoiding corruption and overcoming corruption. It’s because, in the running of a business, we need to hear people’s voices. We need people’s suggestions, their ideas, their insights, their warnings. And it’s just for continuous improvement and the general effectiveness of the organization that you need the leadership in your business to know that creating a speak-up culture is quite the most important single culture change effort to put energy and life into because of all the many business benefits that come from it.

And what I’m going to be doing, as Gio had said, is talk about some theoretical concepts. But the purpose of that is to explain why creating awareness of your hotline is so important and that your strategies must be based on an understanding of why people do not want to speak up. And so, that’s what I’m going to spend a lot of time on today, really helping you understand why people don’t want to speak up. And you’ll be able to develop your strategies and have confidence that those are strategies that are going to be effective. I’m going to move on to sharing my presentation with you now, and hope that you find it entertaining. And look forward to seeing you more directly in person again on the other end.

Gio: As you get that ready, Penny, I just want to encourage and remind everyone that the chat is open, so you can drop your questions in there. We’re going to be monitoring those during the discussion in case we need to dive deeper on anything that Penny’s going for. And then we’ll certainly have time at the end, that’s when we’ll probably do most of the Q&A. But please jump in and ask your questions and we’ll be looking out for whether we can dig deeper on something. And in any case, we’re happy to get back to you at the end or in any follow up. So, with that filler done, Penny, thanks for giving us a great setup and talking to us about how some of these blind spots and these areas that, you know, people aren’t speaking up in can be a real huge area of improvement for us. Really looking forward to the presentation.

Penny: That’s wonderful. So, just confirming that you can see our opening slide, how to effectively promote your ethics hotline. And I thought that it would be quite important for us to start on a humorous note, and humor is something that I’ll come back to towards the end of our presentation. And we’re all familiar with the idea of “hear no evil, speak no evil, see no evil.” And really what we’re talking about when it comes to people not finding their voice in the workplace is the reality that we have a tremendous amount of information that is lost to the organization. So, what we find is that a deafening silence, which is actually potentially deadly and disastrous for the business is something that can be a consequence of the lack of a speak-up culture. Now, I know that many of you are familiar with the problems at Boeing.

I’m going to just talk about two instances where death and disaster have been the consequence of problems with the ethics hotline. And I think it’s really important. These are examples from 2019, and we need to keep them fresh in our minds. So, we all know that this is one of the greatest airlines in the world, and many will be familiar that in October 2018, a flight crashed in Indonesia and that in March the same model aircraft crashed in Ethiopia.

Now, there were significant implications for Boeing, specifically the death toll. Obviously, this is an implication for the people involved. I know right now with the number of deaths we’re dealing with with COVID, 346 deaths may seem a small number, but the point is that they were actually avoidable and foreseeable deaths. If you don’t care about the deadly effect of silence in an organization, I can really hope that what you do care about at least is money. As a business person, 13 billion U.S. dollars was a lot for Boeing to lose in a single day.

But what I think is going to be quite useful is for us to go on, to talk about the business in South America. Pronounced “Vale” in South America, this is the world’s largest mining company of iron ore and nickel. And I’m showing you here their values. If you look in the top right-hand corner, out of interest, their value, and this is taken off their websites and the public domain is “life matters most.” And when I read that, I thought, what a fabulous value to have as the first value that you see. Life was harmed significantly when a tailings dam, that’s a dam that is designed for permanent containment of waste from the mining process collapsed. There were large numbers of cubic meters of sludge from this dam containing toxic material. When the dam collapsed, that toxic material firstly destroyed Vale’s own staff canteen where an entire shift were having lunch.

It went on to be the biggest environmental disaster in Brazil’s history. And again, there was a huge rescue effort to try and locate the people who were lost. Not all of them were found. And again, it was just over 200 or 230 that we believe to be the death toll. Again, the single biggest trading day loss in South American history by Vale was R 19 billion. Now, what I want to talk to you about in the case of Boeing and in the case of Vale was the failure with regard to the ethics hotline. In the case of Boeing, there were no reports to the ethics hotline until about March of 2019, or April, 2019. Calls from experienced and specialist people at Boeing started making their way after the second crash.

There was still silence after the first crash, but after the second crash, people who had been silent until that point in time started speaking up. The other thing that was interesting is that people from the Federal Aviation Agency themselves started making reports that they had known that there was a problem. We don’t know why people didn’t speak up earlier. Obviously, one can come up with an idea as to why that might’ve been, but what I want to tell you about the Vale tragedy was that a lot of people had spoken up and nothing had been done. Well, maybe it’s wrong to say that nothing had been done, what is true to say is that employees reported to the hotline and to management that they believed that the dam was going to fail. However, Vale had a private provider expert quality assurance experts from Germany who seemed to have attested to the integrity of the dam.

So, it’s actually not just the executive from the company, but also from this German quality assurance provider who actually are facing criminal charges right now. So, we don’t want to find ourselves as organizations facing these kinds of catastrophic results that you essentially can’t come back from. So, what we really know is that there has to be a clear path laid out for your employees. They need to know that the path to raising issues exists and what that path looks like, because they really have two options otherwise. The one is to be silent and the other is to go straight to the press. And we certainly know that reputation harm is something that happens in seconds and minutes and can be catastrophic for the organization. So, let’s talk about why often we feel happy if we have very few reports or in fact no reports to the ethics hotline. And what we do know from research and I think it’s been covered in previous compliance line webinars, is that if you have no reports or few reports, this is a bad sign, do not be happy. Okay.

The first thing it tells us is that there’s a major problem with trust in the system. So, people are unaware of the system or believe that it cannot be trusted, that there will be negative occupational consequences for them in the form of retaliation, that confidentiality won’t be retained. What is more concerning is the likelihood that people are not making reports because they don’t care. This challenge of engagement is a very important one for us because when people disengage, what we find is that the care for the organization is part of what has been disengaged. And so, when we’re looking at everything we do to promote engagement is exactly what we need to be doing to promote good ethics in the workplace.

I do a talk on the neuroscience of ethics and I do a talk on the neuroscience of leadership. And it’s essentially the same talk with a different heading, because everything we do to create an environment in which people are going to be likely to act ethically, it’s the same kind of leadership we need in order for people to feel engaged. And that’s a subject for another day. What certainly will happen is that you will find that you will encounter people in some parts of your business, and you may even have had this thought, and that is that the simple way to get reports is to incentivize with money. So, what I really want you to know is that the answer to whether this is a good idea or not is unequivocal, it is a very bad idea. So, if you’re ever faced with the question from a board where someone or from a department where you have people who believe that all decisions are just based on cost-benefit equations, and that money is the major driver of people’s motivations, they will be very keen for you to promote use of the hotline using financial incentives.

The reality of the situation is that money completely corrupts the moral imperative that needs to be at the heart of most people if they are to speak up. And I think that what we do when we, as an employer, offer financial reward to people who speak up, we are essentially calling for them to be paid informants. And as we go through the presentation today, you’re going to see that that can be very damaging in terms of relationships in the workplace. What we want is people to care about the organization, to care about the business and the people, and its future. We want them to be talking from a position of being moved to report because they are very unhappy with the status quo. And the reality is that very few businesses have got pockets as deep as the department of justice.

If it comes to the question of trying to compete with the regulator who is going to potentially award a whistleblower a handsome sum of money, we need people blowing the whistle internally so that we can find out what the issues are and resolve them before the matter goes outside the organization. So, what is it that makes people so reluctant to speak up at work? What I’m going to be doing is just touching on a few examples of insights from a range of different disciplines, some of which you might be familiar with, but they’re all going to make intuitive sense to the people who are attending this webinar this evening. And I hope that they’re going to spark some really useful ideas. So, let’s talk about personality as an example. Many of you will say, “Well, it’s really to do with the person.” Some people are outspoken, some people are reticent, and there’s not much you can do about that.

And this is absolutely true. Some people are just…arrive in the workplace much more prone to speaking out and others very unlikely to speak out. What studies have shown us is that dependent on that context in which a person finds themselves, a reticent person can be more likely to speak up. And certainly, in a deterring environment, an outspoken person will clam up. So, we’re really interested in the environment on the one hand, but I don’t want to move away too quickly from the human beings that we are dealing with because the insights come from understanding how we think, how our brains work and the messages that we have learnt as we’ve been growing up that have left us with strongly ingrained messages about how we should conduct ourselves. So, I’m going to be talking about that. So, certainly, we know a lot more about the brain than we ever did before.

And I’m going to talk about some longstanding insights and some relatively newer ones. When we talk about ethics and we’re promoting the concept of engaging peoples’ right minds at work, we talk about the key role of the prefrontal cortex. That part of the brain that is responsible for us being able to weigh information, assess things accurately, have good judgment and be able to reflect and be self-aware. What we do know is that our ability to act rationally in the way we expect all employees to act rationally can be completely derailed and overpowered by strong emotion. And that is quite simply because the part of the brain that is responsible for attending to our environment, to protecting us from risk, to monitoring threats has a very important survival role to play and keeping us safe, but psychologically and physically.

And in certain environments and under certain conditions raises such alarm bells that our attention is turned to that self-preservation as opposed to what might be our more rational thoughts. So, I just wanted to share with you a very interesting, more recent finding, and that is that the neural pathways or systems that are involved in the experience of pain in the brain, we now know it to be the same or similar, whether we’re talking about physical pain or emotional pain. Now, what is new information and insights for us is that isolation or feeling excluded, the feeling of not belonging has a very, very profound effect on people. The idea of being excluded or isolated from the collective is something that we are engineered to avoid, to fear. And so, it’s quite interesting that when we look at certain studies that have been looking at the impact of, the experience of isolation on the brain, we’re seeing the extraordinary level of actual pain response at the neural network.

I’ll come back to this concept and we’ll build on it by referring to some other disciplines. The other thing that’s important is this whole idea that social pain, for example, the pain of being excluded or humiliated is something that each of us are very attuned to. And so, when we’re in a room with one person who’s being humiliated, we can feel and suffer that humiliation. I can’t feel what it’s like that you have strained your ankle running in the park yesterday. But if I see you humiliated, I can feel that pain. And so, these kind of experiences are very powerful and their effect on people in the workplace.

The other thing we know, and this makes intuitive sense is that there are many experiences we have in life that are very prevalent in the workplace, that almost derail our ability to think rationally because they upset us so much. And one of these is unfairness. Maybe we should just talk about unfairness, injustice, indignity, humiliation as being examples of experiences that put the brain in a state of high threat. And when it comes to unfairness, it can result in a person really acting against their better judgment. And in retrospect, they’re perfectly capable to look back and say, “Well, that behavior wasn’t appropriate,” but in that situation, the unfairness of the injustice or the indignity drove them to behave in an irrational fashion. And this is something that we need to be wary of and use to our advantage. And I’ll come back to that when we look at our recommendations.

Okay. So, one of the things we’re aiming to do in organizations is to create a context that is brain-friendly and it’s popularized in the concept of psychological safety, especially in this book, which many of you will have seen and read by Prof. Edmondson of Harvard Business School. And it’s a very key thing for us to note in this context is that it is the local leader who shapes the person’s experience of psychological safety. You can have all the posters, the programs, all the intention at your highest level to not victimize people who speak up in the workplace, but because the person who has the greatest impact on our work-life experience is actually the supervisor, a simple pause or a raised eyebrow on their behalf is enough to derail your entire communication program. So, bearing in mind that people, especially in a distributed environment, really rely on the first line supervisor as a measure of what the organization’s beliefs are.

We certainly are reluctant to get into bad books or in bad favor with that first-line supervisor. And so, this is an important thing to be bearing in mind, is that as we creating awareness of the ethics hotline, we need to be ensuring that our first-line supervisors and managers at every level know a couple of things. They need to know that it’s actually an offense against the organization to threaten people implicitly or explicitly against speaking up. So, they might say, “I’m not retaliating,” but it’s not actual retaliation, it’s just the hint that there could be retaliation that is enough to stop a person in their tracks. And that is what these supervisors who are trying to contain information within their structure that we really need to have knowledge of at a higher level and to intervene on are doing and intimidating in very subtle ways.

They don’t have to do very much. And that’s the way we’re wired. So, I want to spend some time talking about lessons from social anthropology. And I think what’s very exciting for me is a study that has been done by Oliver Scott Carrie and some coworkers. And what they did was to study 60 societies using 600 sources. Now, this is a paper that was published in 2019. And when we send you the slide deck, we’ll be giving you a great reference list. And what I want to explain to you about the study is that it had very profound findings or what the researchers did was to distill exceptionally valuable information for those of us who work in workplace ethics anti-corruption and compliance. What they did was across all these cultures, which were very varied, they were able to identify seven behaviors that were commonly considered important across almost 100% of those 60 societies. And I’m showing you what they are here. You can read through the list for yourself.

What I need to start by saying is that one of my big frustrations is when I start a leadership ethics workshop, and a manager will say to me, “Well, you know, there’s nothing to be done. If they get here and the parents didn’t do the job, what can we do?” There’s this belief that people arrive or should arrive fully formed in the workplace as young adults, with all the knowledge and ability and expertise that they need to navigate the complex ethical challenges of today’s workplace. Nothing could be further from the truth. In fact, what I want you to know and understand is a lot of these so-called moral messages are not, in fact, moral messages. They are messages that we’ve been given by our caregivers over centuries, all with the goal of encouraging the survival of the group and protecting the functioning of the group through the promotion of cooperation.

And so, so many of the messages that we have, that we describe as moral messages are really messages about the importance of getting along, of not being the black sheep in the community, of not being socially isolated, of fitting in. The importance of fitting in and acting in a way that is going to be seen as co-operative and acceptable to your community is what it is that we learn. So, it turns out, across continents, across cultures, language groups, and religion there’s a lot we have in common. And I’ve just circled check some of the important corporative behaviors that were identified by Oliver Carrie and his team. I refer to it as helping your kin and kind. Essentially, one of the most important things we are taught to do is to put friends and family first. One of the other very important things we are taught to do is to defer to superiors.

Now, if we think about deferring to superiors being such an important message or injunction that we get when we’re growing up, let’s think about the fact that from an early age, we know that to be in good favor with our parents or caregivers means telling them what they want to hear. They’ll say, “Ah, that’s what I want to hear.” And when we get to the workplace, what happens is that just gets reinforced a hundred times over because what we learn very quickly is that our first responsibility is to follow an instruction, let’s hope it’s lawful. And that one of the easiest ways we can lose our jobs is to fail to do so. So, not only are we brought up learning to differ, but we have this emphasized in many ways. And even in law, there’s a requirement that as employees, we follow reasonable instructions. And, of course, we don’t spend a lot of time in induction telling people what’s reasonable and not reasonable. So, what you’ll just be seeing here is how pulled out the behaviors that you will see going with these three messages, and you can immediately see how those actually work against a speak-up culture.

And when we do work on bribery on handing gifts, again, we look at many of the interesting bad messages that are supposedly good messages. For example, nepotism in recruitment is something we really need to teach people that it’s bad, especially if they’ve grown up believing that you’ve got to put your family first. So, here are the behaviors that I wanted to talk about. But if we are wanting people to act with humility and loyalty, we have to be sure that we are positioning who they have to be loyal to. And when they actually should be outspoken and disregard authority early on in the work relationship. On the cognitive science side of things, I’m sure that you are starting to see so much writing in the popular press about unconscious bias. And unconscious biases are essentially shortcuts. They’re very useful shortcuts that help us to form short and sharp opinions of situations or assess situations very quickly without having to use a whole lot of brainpower.

This means that we often deal with or look at the world by applying stereotypes. And these might, in many instances, be good and valuable and helpful and protective to us, but at the same time, applied in the wrong situation they are not helpful at all. But this is what we have. The people who work for us are people who have biases such as the conformity bias. We are taught to cooperate to get along, not to stand out. This is something we’ve seen in Oliver Carrie’s work across countless societies, but we also know that this is a very strong cognitive bias. I do quite a lot of work on anticorruption in the higher education sector where, of course, we have a predominance of people who are often very proud of the fact that they do not conform. But the truth is, in reality, conformity is a strong injunction and message we have. Another is the status quo bias. We just want things to stay pretty much the way we are, which is why we don’t like people who speak up because they really upset the applecart. We know that there is the bystander effect. Well, we’re starting to unravel the extent to which this operates, but certainly, it has long been thought and it’s now the subject of review, that when a lot of other people are in a situation or know about something, we are less likely to feel a personal responsibility for taking action.

I want to talk about lessons from behavioral science. And one of these is the concept of social proof, which requires a bit of a discussion. I’m showing you a photograph of a trolley. I don’t know if you call them trolleys, these are the mechanisms we use to put the grocery packets in when we come out of the supermarket. And there are…

Gio: For all you Americans, we call those shopping carts.

Penny: Shopping carts. Thank you, Gio. I’m glad to know. So, you’re seeing a shopping cart and it’s been abandoned in an area it wasn’t supposed to be abandoned in a mall parking lot. So, thanks to Robert Cialdini, and many others.. really worth reading anything written by Robert Cialdini. There are many studies that show us that depending on the environment, we will devolve to a worse version of ourselves than we would under other circumstances. So, in this study, I’m just using it as an example, they took a parking lot that was dirty with a whole lot of rubbish lying around and badly kempt and poorly painted, and they found that people were much more likely to just abandon their shopping carts without taking it to a designated bay, running the risk that it would damaged another vehicle than if they were parking in a beautifully kempt, clean, neatly painted parking garage. Do you call them parking garages, Gio?

Gio: Yeah, we do. You nailed it on that one, Penny. Or you can call it a car park if you want. We can probably figure that one out.

Penny: Car park. Okay. Great. So, we can move away from the example, but essentially the minute there’s any evidence of other antisocial behavior or any sign of lowered standards, that environment appears to have the effect of giving us permission to lower our own standards. But social proof is an important concept because when we know that other people are doing the right thing, we are more likely to do the right thing ourselves. So, I’ve given you a negative example here, but we need to turn it around in a positive way.

So, I live in a country where corruption is the main headline on the newspaper day in and day out. And I spend a lot of time talking about the fact that it’s only a minority of people who are corrupt. I talk about the fact that there are severe consequences, and I point to the consequences that are being meted out and are being experienced by the friends and family and the perpetrators of corruption, because there’s such a dominant impression that corruption is the norm, which is not the case at all. So, this is very dangerous. What do you do not want is your employees to believe that if they speak up, there will be retaliation. We don’t want them to believe that if they speak up, their identity will be revealed. So, what we’re needing to do instead is to create an environment where there’s social proof or evidence that this is the right thing to do. Now, it’s so tricky because we deal with many reports by employees in a confidential way.

So, we don’t go and take out an advert saying, “92% of people who reported to the hotline were not retaliated against” as an example. But this whole concept of social proof is something that requires attention in the way that we are talking about our programs. Moving on to wanting to talk to you about how we go about… I’m just moving the block of controls out of the way so that I can actually see you again. Okay. So, if we want to create a speak-up culture, the first thing we need to do is to ensure that people know that there’s going to be no occupational harm or detriment that is retaliation. So, we actually need to make retaliation an offense, and we need to make retaliation a reason to report to the hotline. And we need to provide anti-retaliation training to supervisors, and we need to create escalation routes and policies so that it is very clear to everybody in the supervisory chain who they must raise the issue with when someone comes and reports something of concern.

It’s very important for us to show that action will be taken. And I’ve got to just tell you about some changes to the law in my own country, and that is there’s been an introduction of a set of timelines by which feedback needs to be given to a person who’s spoken up. Now, of course, if a person has been calling the hotline on an anonymous basis, it’s very difficult for an employer to give them feedback because you don’t know who they are. One of the things that I think is very helpful is that by having an independent hotline service, as most of you as clients of compliance line do, you have trained operators who in many instances will have given the caller comfort to share their name and confidence and their contact details. So, it’s worth remembering that you can always contact compliance line in response to a report and ask that if they do have the person’s contact details that they get back to them, or that we ask the caller to call back in in a few weeks time to see if there are any questions for them.

And we can actually give an anonymous person feedback if we use our ethics hotline provider as a conduit for that. But when people do speak up internally, we absolutely have to give them feedback in a reasonable period of time. And that includes saying, are we going to investigate this? And if we’re not going to investigate it, giving the person an idea of why that investigation is not happening. We do know people misperceive things in the workplace and not every call is something that requires some investigation.

So, the brain-friendly communication, firstly, must be unambiguous, clear, and consistent. It’s so important that what we doing is communicating regularly. I’m always interested in how companies will put so much money into a marketing campaign for a product or a service. Now, we wouldn’t get marketing department budgets for our internal communications channels, but I do see many more companies putting professional communication messaging skills into play in the communication of human resources messages. We’ve obviously just got to be very important that we guide that those messages are appropriate in light of the many issues that we’ve spoken today that need to be taken into consideration.

We need messaging to be consistent because the brain cannot keep track of absolutely everything we want our employees to be thinking about simultaneously, it’s just not possible. And so, it is no good just creating awareness at the point of entry into the organization, the employee needs to be regularly reminded of the existence of the hotline, of the expectation of the employer, that the employee will speak up, hopefully directly to you. But if not, that they can do so in confidence or anonymously to their hotline. What’s very important is variety. Adopt that your company is using the same campaign or the same single poster to advertise your service or product to clients today as they were five years ago. Certainly, what happens is that we stop seeing things that we see all the time. And that is why variety is very important. And novelty is very important.

And this is a situation where very carefully done without transgressing any stereotypes or offenses, humor, as an example, is something that can provoke attention. We’ve got to grab people’s attention in a very busy world, cluttered with huge amounts of information overload. And that means simply more posters, maybe moving the posters around. You need to be breathing life into your communication campaign, if you want your employees to be taking notes of it. And if you want them to be believing that you really want them to use the hotline and that it’s not just a tick box exercise, because if you find yourself in trouble with bribery having taken place somewhere, you want to go to that compliance checklist and show the investigators from the ACC or the DOJ that you had a hotline. Okay. This is a lot more than that. You need to instill in people a belief that you really want to hear from them, and just mixing up the messaging and putting effort and laugh into it, just as a way of doing it. I want to talk about the values and the culture, and obviously we’re doing that very briefly here.

But the more we create a sense of belonging, the more the employee starts to see the organization as the family, as the kin or the kind, as the collective that needs to be cared for. I’m going back to Oliver Carrie’s work and saying, let’s not have a situation, which is what we have at present, which is where people say, “Well, my group, my people, I’m not going to speak up because I’ll be a snitch and I’m going to risk that very painful social isolation. I’m not prepared to do that.” We need them to be feeling a real bond and a connectedness and see that there’s a link between the future of the business and them expressing their voice, sharing information that we may not have. And that needs to be made clearly. I often start ethics training with employees talking about, let’s talk about a company that’s had a terrible reputation catastrophe.

Let’s talk about what’s happened to the people there, what it would be like for you if you went home to your family and you had to explain yourself and you were believed by the community to be guilty by association? Really starting to get people to see that what happens in the organization really is directly important to them. So, the business that they work for, their employer must be their kin. One of the other things that’s important is that the value of fairness and of dignity or the values of fairness and dignity are your real friend. Because if you empathize them, there’s nothing like the outrage against unfairness to prompt people to make a report to a hotline. People will often tolerate unacceptable, even criminal behavior like bribery or being on the wrong end of that bribery up to certain point beyond which they experience outrage.

Everyone has outrage at different stages in response to a similar situation. And by emphasizing fairness, we find ourselves much more likely to get outrage-driven reports, and you mustn’t be prejudiced against them. If bribery is happening in the business you want to know about it. And in many of the cases that I’ve dealt with, it’s been because the person acquiring the bribe that is to…bribe to be given over time as a good example, earn extra money, or to get a promotion, the person just raised the price or required more, and people just decided that’s unfair. Now, the person’s gone too far and suddenly bribery that they’d lived with for years, they were suddenly reporting and we were able to get on top of. What is very important is for you to be following some of the latest research that is coming out from the field of behavioral science on promoting social courage and pro-social behavior.

I think that one of the things that I think is a huge opportunity for us is to refer back to the study and note that one of those seven behaviors, the messages, the injunctions that we have got as we have grown up is the value attached to being brave. And this is why a lot of work being done in this field now, of getting people to speak up and to use the ethics hotline is really around promoting courage. Don’t stand by, stand up, which is a much more evocative message that will talk to the injunction to be brave than is the message of, if you see something, say something. So, I’m just giving you examples of how we can look at what we know about the brain, what we know from the social anthropology, from understanding people’s fear of social isolation, to ensure that what we do is to create an environment in which then messaging is encouraging people to be brave, to often…just to speak up for others because that’s easier to do than for yourself.

And what I want to do is to just show you the slide, which I find quite helpful. And that is to say at any one point in time as employees, we are on a journey towards being our best self or our worst self. Unfortunately, we are all susceptible to adverse influences when it comes to being our best self. But the good news is that we are suggestible to positive influences. And so, the effort that you put into your communication and awareness campaigns and the passion and the care that you bring to it will make a very big difference. But above all, I hope to have given you a sense of what bravery is required in order for people to find the hotline. And the only way we can be sure that we’re doing the best possible job is to encourage people to believe and to deliver anonymity.

If you’ve got a third-party provider as ComplianceLine, you’ve made the first major step. But the important thing is that your promotional material must not lose sight of the ongoing promotion of the idea of anonymity. And I’m really pleased that you’re going to be getting a free take away from ComplianceLine for attending this evening, and that is a poster that you can use that picks up on the anonymity concept. And just out of interest, there is a article I wrote on creating a speak-up culture, which goes into some of these concepts in more detail, you can just download it off my LinkedIn profile. And if you’ve got any interest in my Elevating Integrity program, which is run on a live online basis and modules for people of all levels in different sectors around the world, you can make contact with me.

But the one message that I want to leave you with before we go to questions is the image of the lighthouse. So, whether you’re in human resources or compliance and governance, risk and ethics, when it comes to creating the speak-up culture, and specifically when it comes to promoting your hotline, you just have to see yourself as a lighthouse. So, let’s talk about the features of a lighthouse, and you can use this as your guiding metaphor. Firstly, the regularity with which the light shines, it never misses a beat. It shines regularly. The next thing is it cannot be overlooked. If a ship at sea is within the radius of that lighthouse, it will be seen. All right. So, your message has to be seen. The role of the message is to shine light in dark corners. You have to put more energy into communicating to your remote sites than to your head office.

You have to be thinking about those people who are there possibly cowered in fear by a local level supervisor, and the only way that you can sleep well at night in the role that you have is to know that if those people are suffering occupational detriment at the hands of a particular local leader or have very critical information, you need that they know, that that hotline can be relied upon. So, as the lighthouse, you are there, you are ever-present, you are unmistakably unavoidable, and your sole role is to warn of danger and ensure that people get to safe harbor. And I hope that that is a useful metaphor for you to finish on. And I’m going to be handing you back as soon as I can.

Gio: Oh, let’s keep that slide up, Penny.

Penny: The lighthouse. So, go there to the lighthouse, Gio. You like the light house.

Gio: I was going to say the one with you and all your excellent qualifications on there. But yeah, if you can keep the slides up, I want to maybe look at those seven common ethical lessons that we get. And then we have a couple of questions here that we’ll definitely go through the next five minutes and may finish up a few minutes past the hour. As we get into questions, I just want to remind everyone that we’ll be looking through all your questions. You’re welcome to follow up with us directly at insightsatcomplianceline.com or any of our emails that you have. And we’ll be sending around SHRM credits and slides and some free giveaways for everyone who’s attended. So, as we get into that, one question for you, Penny, is what do you feel like is the best way to rebuild a psychological safety, which you mentioned as really key in getting a speak-up culture? How do you rebuild that in a toxic environment where it’s been compromised?

Penny: I have the perfect slide to answer this question, it’s just not in this deck.

Gio: Okay. I love sending people answers to questions for later, but we can just chat about it.

Penny: Yeah, no. I think that what is very important is that the human brain needs consistency and reliability. We’re very clear about what we need for a psychologically safe environment and it’s the opposite of a toxic environment. And it’s very difficult for us to rebuild trust in a leader who has effectively abused their staff. It’s the same as any abusive relationship. So, a lot of it comes back to the issue of a change in leadership. If we can help train a person, that would be a very good thing. I’ll give you an example of one of the things that I often use in my training, is to say to supervisors, “Just show me what do you do when someone brings you bad news.” And I then spend time talking to them about the importance of faking complete calm when people bring bad news. Because what people are looking for is someone that they can trust to hold the information, not someone who is unpredictable. They’re looking for someone who can hold the information and then respond to it in a considered way rather than themselves getting angry, which is experienced as retaliation in the moment and obviously highly undesirable. So, a toxic culture, typically, I’m afraid involves the removal of the individual who’s the cause of the uncertain, unpredictable, volatile, and demeaning environments. But I’m happy to have a separate conversation about that.

Gio: Yeah, that would be great. Maybe we can follow up on some of that stuff. Clearly you’ve thought about it and there’s definitely some things that we can do to start kind of correcting that culture. But it probably takes to your point some sustained effort for people to have that psychological consistency and reliability to know that, you know, that that prior experience and those prior actions are in the past.

So, can we talk a little bit about specification and localization? I know that you work internationally, Penny, providing training and consulting across a bunch of different regions. How do you think about this with different country requirements on confidentiality and whistleblower protection versus kind of global policies that a company. And then maybe even down to, you know, how is this different based on different people that we hire and, you know, how do we balance the need to kind of speak to people where they are versus kind of be prevalent across, you know, all our global locations?

Penny: Right. So, I think what’s important is if we just answered in the context, for example, of an awareness campaign, you do want consistency in messaging. What we need to do is to remember that good messaging is going to talk to the majority of people. And this is why I come back to why the Oliver Carrie’s study is so important. We spend so much time looking at difference, Gio, and imagining that we need to package things differently. And, of course, there’s this whole…it’s truly a mix of all these different generations. And now we have different communication strategies for generations, but that’s another discussion to have. So, we really need to say, what is common to all people? We all have the same brains. Most of us are brought up with the same social messages. And so, let’s first design our program of awareness and our speak up culture program around what we know is common to all people. It’s then in the actual technical manifestation of that to your audience that you’re going to partner with a local person in another country.

I’ll give you an example. It is very easy to cause offense when you’re working across cultures. And you don’t cause offense by breaching the local things that you need to understand. So, for example, the idea of blowing the whistle might be not taken well if it’s a referee blowing the whistle. But in one culture, it might be if it’s the linesman, I don’t know if you say linesman or assistant referee, the person who’s responsible for pointing out that there was some kind of transgression and asking someone to look at it and saying, “That’s what we’re doing. All we’re asking you to do is to be the linesman,” the person who asks someone else to come and say, “Is this okay?” And that will work particularly well. I had one client [inaudible 01:00:10]… And so, we’ve got to tailor it to the local situation and detail of the messaging, but the broad messages can be common based on our strong sense that certain messages are needed by all of us wherever we are in the world.

Gio: That’s great. I think that’s really helpful because I think it’s something that we struggle with of, you know, do we just translate the poster or do we do a completely different format in this country? And I think you’ve given us a great framework that, you know, we can start with the things that are universal. We all have the same brains, the same tendencies where we value bravery and being part of a tribe and things like that. Maybe look at what would offend someone and be particularly kind of abrasive in that culture. And that’s going to kind of cover a lot of it. And then you can look at how you can, you know, maybe focus on problem areas or kind of big presence and localize it around that. So, this has been really wonderful, Penny. Not surprised, your writing, your teaching, your training and your consulting are always so thoughtful.

You have such deep experience in this field working across, you know, borders and companies and different divisions. So, I really appreciate you sharing your thoughts with us and our audience today. On the screen here, if you’re still with us, we’re going to be sharing these two posters for you to just do a refresh. If you’d like, you can customize them, put your phone number and an email or a website on them and your logo and, you know, have your internal team customize them. But we’re going to be giving you these three posters as a thank you for sharing some of your day with us, as a way to, you know, reference trust, build something that’s fresh. You know, Penny was talking about that lighthouse, you know, it’s always moving, it’s always spinning.

It’s always visible. And just give you a chance to refresh this. Please know that Penny does great advisory work around these programs and how to roll this out and how to get your messaging right. We’re also happy to help you with these things here at ComplianceLine. Ultimately, the point of this webinar and the point of so much of what we do is just to help caring leaders, make the world a better workplace, help you be the hero within your company that helps take care of people and make things better. Penny, you’ve helped us greatly in doing that today. I appreciate so much your time and your thoughtfulness about this. And we will be following up with people to send you your SHRM credits, send you slides, and answer any questions that you have. Anything else, Penny?

Penny: Nothing from my side. Thanks so much for joining me today, and the opportunity to work with ComplianceLine with a background in HR and now totally focused on ethics compliance and anti-corruption. It feels like a good home for me to spend time from time to time. Thank you, Gio, and the team at ComplianceLine.

Gio: It’s a pleasure having you, Penny. You’re welcome in our home anytime. It is just great working with someone as thoughtful and professional as you, that cares as much as we do about getting this job done right. Thank you everyone for attending. Please feel free to email us if you have questions. Otherwise, in the next day or two, you’ll be getting some follow up with us with slides and some of these great free posters for you to refresh some things or just even to work some of these images and things into emails that you send around, or other of your communication strategies.

Thank you for joining our webinar on hotline awareness and how to effectively promote a speak-up culture. We’re here for you if you have any questions, and hope to see you on the next webinar.

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