The Cart, the Horse and the Heat Map

While thinking about driving back from a week of vacation out of Istanbul to our house in the city, I am starting to look at the traffic and the inevitable congestion that will build up in the next hours as a few million people will return from their 9-day Ramadan holiday to their homes. After […]

The bottom-up orgchart

I was drawing up some slides on the results of my annual Ethical Climate Survey yesterday when I came to the unavoidable “Tone from the Top”. At that point it struck me how this choice of expressions transports the notion of a classical pyramid-shaped hierarchy. I asked myself how this is supposed to fit with […]

Culture, Compliance … and Turkey – Part 1

Effective Ethics & Compliance in the Context of Turkish Culture Introduction In 2017 I first wrote a blog post about Culture, Compliance and Turkey with a first discussion of the 6 dimensions of Turkish culture according to Geert Hofstede and their meaning for compliance management in this country. In the beginning of 2019, the Turkish […]

Effective Compliance Trainers Treat People Like Adults

In his May 2nd “Compliance Perspectives” podcast, the SCCE’s Adam Turteltaub had an interesting chat with Steve Priest of Integrity Insight International. Amongst other topics, they discussed that a main failure of Compliance trainings has been treating employees “like children”, teaching them rules over rules, to best remember them by heart and telling them not […]

The Law of Large Numbers, Central Limit Theorem and Strange Attractors – or The Strange Behavior of Turkish Employees Towards Limits

This post is not about mathematics or physics but about the behavior of people in the presence of rules and limits … in Turkey. When we discussed revising our Company’s expense limits to account for the currency devaluation, soaring inflation and resulting price increases in the hospitality sector in Turkey in the last months, I […]

Reading list 2019

To continue my 2018 reading list, I am adding here the books (including e-books and audiobooks), online courses, articles etc. I am reading throughout this year. I do a lot of reading (and listening while driving in Istanbul traffic) for my personal interest as well as my engagement as leader of the Working Group for […]

Culture, decisions and enlightenment.

In a recent post on my LinkedIn timeline I read: “After 5 minutes from our birth, our families decide our names, nationalities and religions. And then, most of us will spend the rest of their life fighting blindly for things they have never chosen. Unfortunately this is the reality. If we do not go through […]

Why your car cockpit doesn’t have a heat map

When I was recently making my way through Istanbul to meet my wife for dinner, I was using Google Maps to take me on the fastest route through the evening rush hour. My wife was waiting at a gallery opening in Nişantaşı in the European part of the city and I was coming from Sancaktepe […]

Reading list 2018

2018 was a year of learning for me. As the year draws to a close, here’s a more or less complete list of the books, audiobooks, blogs, MOOCs I have read, listened to or studied throughout this year. They have inspired and helped me to develop a much wider frame of perspective and deeper understanding […]

Iatrogenic noncompliance – a case study of ethical blindness

Some thoughts on organizational justice Organizational justice is the dominant factor determining how employees perceive their organization’s culture of integrity. [1] Management must meet misconduct with decisive, consistent, visible and effective action as a deterrent for recurrence, and as a clear sign that misconduct is not tolerated. But where exactly does misconduct begin and how […]

Measuring for success

Recently a fellow compliance officer from the Turkish subsidiary of another multinational contacted me. She asked for my advice, because she had lately felt a loss of motivation for her job. After having heard me speak at a meeting of the Turkish Ethics and Reputation Society [1] and having followed some of my posts on […]

Beyond Awareness

It started with the COSO Internal Controls Integrated Framework published in 1992: Control Awareness was pointed out as a key element of an effective control environment. [1] The argument is logically appealing: If employees and managers aren’t aware of internal controls and their importance, how are they supposed to apply them consistently and effectively? I […]