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 […]

Risk exaggeration – a cognitive bias case study

Bribery and corruption are bad. Sectors dealing closely with the government have a propensity for bribery of public officials. Companies in these sectors particularly should implement sound Anti-Bribery Due Diligence (ABDD) policies and procedures. In countries with a low score in Transparency International’s Corruption Perception Index (CPI) [1], the risk of bribery and corruption is […]

Naturally biased – Why internal auditors cannot adhere to their own Code of Ethics

Independence and Objectivity The hallmarks of the Internal Audit profession are Independence and Objectivity. Without independence and objectivity there can be no truly effective auditing, because conclusions snd expressed opinions could be unfairly biased. “Independence is the freedom from conditions that threaten the ability of the internal audit activity to carry out internal audit responsibilities […]

Ikigai – an expression of personal integrity

Ikigai (生き甲斐, pronounced [ikiɡai]) is a Japanese concept that means “a reason for being.” It is similar to the French phrase, raison d’être. Everyone, according to Japanese culture, has an ikigai. Finding it requires a deep and often lengthy search of self. [1] “I am doing work that has both meaning and impact and that […]

Culture, Compliance and Turkey – Overview

This is an overview of the posts I’ve written on Turkish culture and how it affects the efforts to establish and run an effective Ethics & Compliance program in this country. Culture, Compliance & Turkey: This first post, written in 2017, continues to receive a lot of attention. I have taken the topic up in […]

The Carryover Effect of Reputation Risk

Trust and reputation are assets. Corporate leaders are realizing that it is no longer sufficient to be just compliant with rules and regulations, and with the letter of the law as it is written today; instead organizations have to aspire much higher and constantly try to meet and exceed stakeholders’ and society’s expectations. Otherwise, trust […]

Ethical Fading – the hidden erosive force on Integrity Culture

Introduction The focus on effective Ethics and Compliance Programs based on values and principles has been steadily increasing in the past years. “To prosper over time, every company must not only deliver financial performance, but also show how it makes a positive contribution to society. Companies must benefit all of their stakeholders”, wrote BlackRock CEO […]

The limits of our language…

If you are a parent, you may be familiar with the fact that there’s a big difference between telling your kid who is climbing dangerously on a high tree: “This is very dangerous! Careful, or you will fall down and break a leg”, and saying: “Wow, you are very high up, but if you are careful and watch where you are putting your hands and feet, I trust that you are going to do great. I am here watching you and can guide you. But I know you can do it on your own.”

Losing with Integrity – Two Integrity Tales

“Winning with Integrity” is the wording you would usually expect, as you find it for instance in the heading of GM’s Code of Conduct or Leigh Steinberg’s book. But here I will write about successfully losing with integrity. Losing weight, that is. Like my previous post on Integrity and Turkish Coffee, this post is about […]

Measuring Integrity – a basic model from first principles

In a recent post I wrote about Turkish Coffee and reflected on three dimensions of Integrity in the „Head-Heart-Hand“ (3H) model used also in competency assessment and people development. After giving this some more thought, I have slightly amended the interpretation of Integrity in the 3H-model and am starting to think this could be used […]

What‘s in a name?

What should the function or department be called that is responsible for Compliance Management? And what should the job title of the head of that function be? What‘s in a name? That which we call a rose By any other name would smell as sweet. – Shakespeare, Romeo and Juliet (II, ii, 1-2) While I […]

How can internal audit really add value?

At the end of October I attended the 21st International Turkish Internal Auditing Congress, organized by TİDE, the Turkish IIA, here in Istanbul. On the second day Paul Boyle, until very recently chairman of the IIA of Britain, gave an interesting speech with the title: „How can we market Internal Audit better to our Stakeholders […]