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The “Coffee and Naps” School of Business Ethics Training: Part 2

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The “Coffee and Naps” School of Business Ethics Training: Part 2

Part 2: The Chief Culture Officer and the Chief Compliance Officer: Best Friends Forever

In Part One of this series, we discussed how to complete an ethics audit and culture snapshot. Today we’re going to explore the importance of your relationship with your CEO (or Chief Culture Officer) in building an ethical culture.

Imagine that you’re the Chief Compliance Officer of a 50,000 person company. You’ve been tasked with building an ethics program, but you realize that the company has some cultural practices that don’t always encourage ethical behavior. Do you take your concerns to the CEO, try to reform the culture purely through business ethics training, or implement an ethics program that worked well at a past company?

You can probably guess that this is a trick question. You know that your business ethics training program, as well as all the other components of your ethics and compliance program, is only as strong as its foundation: the company culture. That seems quite daunting to tackle by yourself. It’s time to involve your company culture leader.

Some companies have a Chief Culture Officer. Ken Oehler makes a very effective argument in favor of a dedicated culture staff member: “Many companies are seeing macroeconomic pressures that have created a dysfunctional culture, one that is not supporting business performance moving forward, and now, are trying to figure out how to keep their culture from spinning out of control.” Check out three more companies that have dedicated culture staff.)

However, in most companies the role of Chief Culture Officer falls squarely on the shoulders of the CEO. He sets the tone for the behavior, attitude, and expectations, which are the building blocks of culture. He’s also in charge of managing communications and outcomes if negative cultures develop. You can also see how this is a problem that increases exponentially in complexity with any scale to the company. Sure, managing the culture of a 10 person company, while very important, is not all that difficult. It’s a lot easier to keep a pulse on your employees when your farthest away employee is at the end of the hall. Once you get to multiple locations, multiple countries, thousands of employees, culture becomes more difficult to manage.

Luckily you can take some of the weight off your CEO’s shoulders. Working together on the implementation of a scalable system builds the foundation that you need for your ethics and compliance programs, as well as the foundation the CEO needs for optimal productivity and financial success. (Read my colleague Cindy’s post on why culture is a financial necessity for your organization.) Once the foundation is built, maintenance becomes a regularly scheduled part of your ethics program.

Your Business Ethics Training Program and Beyond

So let’s go back to our fictional scenario: You realize you need to go to the CEO for help. You also know that he’s very busy, so what do you really need his help with, and what can you take off his plate?

Define the Cultural Expectation

Work with your CEO to define what the company expects of its employees in terms of culture. At The Network, we have what we call a “See Something, Say Something” culture, commonly referred to as a “Speak Up” culture. We really value our employees speaking up. If you create an environment that makes employees feel comfortable speaking up, situations are often nipped in the bud before they become full blown problems.

The United Front of Ethics

Profit isn’t the only thing that matters. How it’s achieved matters too. This is what I call the United Front of Ethics – making sure everyone knows that you and the CEO are on the same page and have the same expectation for ethical behavior.

Remember when you were a kid, and you knew if you asked your mom for ice cream, she’d say no, but if you asked your dad, he’d cave every time? Perfect example of what a front that’s not united looks like. What does this look like in the corporate world? An employee that’s struggling with a decision that sounds profitable, but also unethical. While he knows what you set forth in your business ethics training program clearly defines this as an offer he should decline, if he feels his performance is measured purely on profit, he will likely take the offer.

You need the CEO to be very vocal about the cultural expectations in order for them to be effective. An employee who knows his company values ethics is more likely to act accordingly, and also report the incident. After all, would you bother reporting an ethical violation to management if you knew the company only cared about its bottom line?


While the past two steps have involved collaboration with your CEO, the first part of this step is your time to shine. Putting together your Code of Ethics, Code of Conduct, and business ethics training program is right in your wheelhouse.

Once you’ve gotten the first draft together, meet with your CEO to discuss current initiatives within your company that could be integrated into the theme and visual elements of your Code of Conduct and ethics training.

For example, Newell Rubbermaid came to us with ambitious growth goals for the year ahead. They had recently completed a string of acquisitions and added a large number of new employees as a result. The CEO and CCO really wanted to stress the importance of growing with integrity across the whole organization, and “Growing with Integrity” became the theme for the campaign. You can see samples from their Code of Conduct design here. The campaign was so successful that we received a joint award with Newell Rubbermaid, the 2012 Gold Quill Award of Merit from the IABC.

The CEO must also have some sort of a presence in all of the previously mentioned documents. Whether it’s an opening letter or notes throughout, make sure that it’s clear that he’s a part of this initiative. We’ll cover in-depth how to design each of these elements for maximum efficiency and retention in part 3 of this series.


I might be biased as a marketer, but how you promote your values matters just as much as what they are. If your employees don’t know what you expect and value, how are they supposed to live up to those expectations and embrace those values? The CEO should support his presence in the Code of Conduct and Code of Ethics by being vocal about the values of the company.

How you promote your new program and materials depends on whether you want to use all digital tools or include some paper materials as well. Many of our clients find success with a combination of the two. It’s funny how quickly things have changed – it used to be that getting an email was an exciting novelty, but now that you almost never receive paper anymore, getting any sort of a physical document stands out. Creating a desk drop of some kind, such as a brochure, a sticker, or a magnet, may help the program launch, while a digital home for your ethics documents provides easy access for everyday use.


As you review your quarterly and annual metrics, you may find areas for improvement that could become part of next year’s initiative. Keep a running report of ideas you’d like to incorporate as they pop up, and you’ll have a great list of ideas to kick off next year’s planning meeting with your CEO.

What’s Next?

Now that you’re in sync with your CEO, you can move on to the fun stuff: implementation. In the last part of this series, we’re going to dive deep into the deliverables of a successful business ethics training program and best practices for how to create, implement, and promote each piece.

For More Information on Business Ethics Training, Check Out These Resources:

Blog: Code of Conduct, Training & Policies: Three Keys to Building a Culture That Values Ethics & Prevents Retaliation
Blog: Employee Retaliation and 5 Steps to Stop It
OCEG Webinar: Preventing Retaliation With a Speak Up Culture

About the Author

Pia Adolphsen, Associate Manager of Marketing Content Strategy. Pia leads content strategy at The Network. Previously, she led client advocacy and marketing initiatives in the competitive intelligence industry. She is strongly in favor of lattes, 1.0mm pens, and her Georgia Bulldogs. Connect with Pia on LinkedIn

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