At the Organisation for Economic Co-operation and Development (OECD) Integrity Forum in March 2017, the OECD concluded that a narrow focus on anti-corruption and fraud prevention has proven insufficient, and companies must broaden their approach to building “cultures of integrity.” Since then, social and political dynamics have further sharpened the need for companies to rethink corporate purpose, values, and ethics beyond compliance. In other words, it is time to launch Corporate Integrity 2.0.
Corporate Integrity 2.0 means considering ethics and integrity across the organization, not simply delegating ownership to the compliance team or responsible business functions, and managing this as much more than a response to regulatory risk. It involves using the latest behavioral research to shape decisions on governance, incentives, and oversight and working collaboratively with other organizations in the public and private sectors to tackle systemic social challenges. It entails considering the meaning of corporate values and understanding that these are determined in practice by strategic decisions, reward structures, and political and commercial relationships.
As BlackRock’s 2018 letter illustrates, the mainstream investment community is becoming increasingly vocal in its demands for companies to demonstrate social value. Businesses are also being called to step up and take action on a range of societal concerns, such as tax transparency, lobbying, inequality, immigration, women’s rights, and climate change—all areas that traditionally sit more squarely in the realm of public policy.
In response to these dynamics, there has been a notable growth in willingness of companies to take public positions on key issues, and several commentators have noted the rise of “CEO activism” as part of a new effort to engage with society in a more impactful way. Questions of corporate values and purpose are front and center in the minds of senior leadership teams, and this trend is only set to accelerate.
One question that has received far less media attention is what this means for how companies structure, manage, and organize themselves internally. Shifts are occurring here, too, but progress is far more incremental, and many companies tell us that they lack concrete direction on their next steps. As we have argued elsewhere, how to build and sustain an organization whose employees are happy, motivated, and ethical is one of the most complex, elusive questions confronting business leaders today.
As the OECD’s upcoming paper on behavioral insights for public integrity argues, creating cultures of integrity is a complex and multilayered effort. Employees need support and guidance on the ethical aspects of their daily decisions, but the cues an organization gives via its structures and management decisions are equally important.
Most compliance programs assume that individuals are rational actors making cost-benefit calculations, deciding to avoid misconduct if they perceive that the likelihood of detection or punishment outweighs the benefit of the wrongdoing. However, a compelling body of academic research suggests that this is not the best way to understand unethical behavior. Humans have a propensity to rationalize and justify their own decisions, and the organizational and group context is of overwhelming importance in this regard. Risk is increased via a range of factors, including role stress, poorly designed incentives, time pressures, diffuse accountability, and overly draconian preventative regimes. Companies have a huge opportunity to incorporate these findings into their programs today, and in the process can reduce the enormous cost and compliance burdens of approaches whose effectiveness is questionable at best.
We think there is a bigger opportunity to more cohesively align the ethics and compliance and sustainability agendas within organizations. Given what we know about how humans are motivated, how they respond to situational cues, and how fear of punishment may have negative unintended consequences, the compliance team needs more tools in its arsenal to inspire, drive pride in the organization, and demonstrate a commitment to values that are about more than competitive advantage and growth. The work of sustainability teams to use business’s energy and innovation to drive positive change is invaluable in this context.
Many — if not most — of the pressing strategic questions facing corporate leaders today do not fit squarely into the remit of a single department. To drive coherence and alignment around values and integrity, we are working with companies to create advisory groups, board committees, or cross-functional management teams with representatives from various functions. This process challenges companies to pay more attention to the relationships, resources, and power available to different groups and teams. If rhetoric and resources are out of sync, that will be highly visible across the organization, and employees will draw their own conclusions about what is truly important. But when these governance approaches are designed using behavioral best practice, they provide the possibility of an entirely new approach to managing integrity.
Companies are re-examining their core values, stakeholder concerns, and the way they make decisions across diverse areas, such as policy engagement, lobbying, marketing, and risk. This has created the possibility of transformational change in tomorrow’s organizations, which is why I believe it’s time to launch the era of Corporate Integrity 2.0.
Alison Taylor, managing director, sustainability management, leads BSR’s sustainability management practice. She focuses on approaches to sustainability through risk management, strategy, stakeholder engagement, transparency, ethics and governance, and organizational change.