Just under one-third of corporate executives participating in a recent survey are highly confident that their companies' employees will report unethical behavior.
The report, titled "Global Ethics and Compliance in Uncertain Times: Leveling the Playing Field," is from consultancy giant Deloitte and reflects the responses of more than 930 C-suite and other executives who participated in the survey during a Deloitte webcast in May.
The No. 1 reason executives believe that, despite regulations, employees struggle with ethics and compliance? The inconsistency of clear, concise and frequent ethics program communications and training for all employees.
For that reason, Don Fancher, Deloitte risk and financial advisory principal and U.S. forensic leader, recommends that companies evaluate their training programs, considering factors such as whether the programs are interactive, if they are delivered virtually versus live and if they include new material addressing regulatory and compliance issues that may have arisen in the past year.
"What really works well is not just giving the information but putting examples in front of the employees and having them role play," Fancher said in an interview. "It puts them in a more normal situation and allows them to say: 'How would I respond?'"
He also urged companies to consider the global nature of training programs and to tailor them accordingly, noting that relevant ethical issues may vary from country to country.
The survey also found:
More than half of respondents 52.4 percent say global corporate ethical behavior has improved since the enactment of the federal Sarbanes-Oxley Act in July 2002.
Only 41.3 percent of respondents believe their companies' global ethics cultures are strong.
In addition to inconsistent training, the other challenges to employees' compliance with global ethics programs are the lack of incentives and repercussions surrounding ethical and unethical behavior respectively, varied ethical postures of third parties with whom employees regularly interact and differing ethical standards for various employee groups.
A company's general counsel or chief legal officer has "a significantly important role to play" in improving employees' compliance with global ethics programs, Fancher said. Combining the GC's experience of responding to an allegedly unethical situation after it occurs with the chief compliance officer's duty of implementing proactive measures to prevent such conduct provides the company with a "more modern response" to ethics and compliance, he said.