by Steve Koslow
The proverbial holy grail of ethics and compliance programs is a speak up culture where employees freely offer their thoughts, opinions, and concerns. A cultural atmosphere of psychological safety where employees feel, in their core, that their voice is welcome. In these environments, employees openly discuss where behaviors may be contrary to their company’s values or may be needed to further these same values.
Importantly, a healthy speak up culture goes much deeper than identifying and addressing unethical behaviors. It demonstrates the critical distinguishing factor between those companies where innovation flourishes and growth accelerates, and those companies that struggle to remain relevant.
Allianz Life is embarking on an aggressive growth strategy that includes the introduction of new products, to new markets, using new technology and capabilities. At the heart of our strategy is the structural dissemination of decision-making away from historical hierarchal structures and down into the heart of our business operations. Smaller and more concentrated teams are necessarily empowered with significantly greater decision-making without many of the traditional checks and balances that existed with layered, and time-consuming committees. Decision-makers at all levels of the organization need to get it right and their reliance on the knowledge, experience, and views of their teams has never been more important. More than ever before, decision-makers need to hear the voice of their teams, not only to avoid the risk of making a bad decision but to gain the insightful sparks that generate true innovation.
If leadership is not hearing the voice of employees when it comes to directional concerns or innovative ideas, they will certainly not hear the voice of employees who are concerned about behaviors that do not align with a company’s values.
For years, ethics and compliance professionals have discussed, examined, and explored how to strengthen speak-up culture. We have clearly moved the dial with greater focus on anti-retaliation and meaningful action. It is difficult to imagine a code of conduct that does not strongly convey that retaliation for the raising of good faith concerns will not be tolerated…and back up that precept with the careful tracking of individuals who do raise concerns. Moreover, meaningful investigations will result from the raising of these concerns. However, notwithstanding the great work of ethics and compliance organizations across the country, more is needed. For example, according to the global culture survey dataset in Ethisphere’s data benchmarking platform The Sphere, only 73% of all companies surveyed specifically covered “viewing reporting as a positive opportunity to address issues” as part of their non-retaliation training for managers. And only 71% covered “observation to prevent retaliation from co-workers” in manager training, as well.
If there was a simple, single, answer to this challenge, we would have discovered it long ago. As an ethics and compliance community, we need to explore, experiment, and share more ideas that can help us collectively move this extremely complex but vitally important dial even further.
At Allianz Life, we are experimenting with a concept (that we readily admit may not be new or unique) to help us on this important journey of creating a sustainable and viable speak up culture. Simply, we are working to shift the paradigm from the traditional “speak-up” culture to one that is more of a “hear me” culture. When management tells employees to “speak-up,” management retains the power and authority; management is directing employees to take an action. In a “hear me” culture, employees retain the power and authority inherent in all human beings, regardless of positional authority, to be heard. We do not simply want management directing employees to speak up, we want an employee directing management to hear me, and for management to really listen to what the employee is saying. At Allianz Life, our company values of Integrity, Caring, Excellence and Respect embody the concept that all employees have a right to be heard because their thoughts, ideas, opinions and concerns are important and have worth.
In 2023 we kicked off our “Hear Me/I’m Listening” campaign with employee articles, leadership discussions, surveys, and town halls across the company. We worked from a very simple set of principles:
Everyone deserves to be heard. Everyone has ideas, opinions, and concerns that are worthy of consideration.
We do not always have to agree, but can commit to listening and discussing everyone’s ideas, opinions and concerns.
No one should be penalized or criticized for voicing their ideas, opinions or concerns in alignment with our values.
As we all know, a single campaign does not a culture make. Now the hard work begins. In 2024, we are committed to holding numerous focus groups where we can hear from employees across the company about what is and is not working. Where are there micro-environments in our company where employees feel and do not feel heard? How do we leverage, replicate, and celebrate environments that are working and adjust those that are not?
We will be having focus groups with employees and separate focus groups with managers to gain all perspectives in safe environments. We will be talking with managers and leaders from across the company to better understand what is working and what is not working in their desire to effectively listen to the voice of our employees. In addition, we will continue with spot surveys to assess the state of our “hear me” culture.
Importantly, we will be turning to the Business Ethics Leadership Alliance (BELA) and the amazing readers of this publication for additional ideas, examples and thoughts.
While we do not expect to solve this complex challenge and magically create a perfect speak-up culture in the next year or two, we hope to move the proverbial dial in helping employees feel more comfortable raising their voices to be heard.
To learn more about Steve’s insights on the Hear Me/I’m Listening campaign, check out “How Active Listening Creates a Better Speak-Up Culture” on the Ethicast.
ABOUT THE AUTHOR
Steve Koslow is Chief Ethics and Compliance Officer of Allianz Life Insurance Company of North America. With more than 20 years of experience in the financial services industry, Koslow has broad knowledge in the development of ethics and compliance programs for insurance companies. He has experience leading large, complex ethics and compliance organizations and is an industry innovator in the areas of ethics, analytics, and risk management.
