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Avoiding the Bad Apples

The risk of costly compliance investigations and fines in FCPA, anti-bribery, and supply chain corruption keeps corporate executives and compliance officers up at night. Robust training programs, well-staffed monitoring and testing departments, and expensive compliance technology can reduce these risks, but some portion of risk rests within the character of the individuals in key business roles.

How to Hire For Integrity

Written by Destree Rickard

The risk of costly compliance investigations and fines in FCPA, anti-bribery, and supply chain corruption keeps corporate executives and compliance officers up at night. Robust training programs, well-staffed monitoring and testing departments, and expensive compliance technology can reduce these risks, but some portion of risk rests within the character of the individuals in key business roles.

After a reported violation, most compliance executives find themselves asking the same question: Is this a systemic or an isolated event? Once investigated, headline after headline reveals the same conclusion: the corruption begins with one individual. Basically, one bad employee spoils the reputation of the whole company.

When you consider the harm one employee, or just a few, can do, it begs the question: How can you spot the bad apples and hire people with integrity?

If your company is like most, the compliance department is the backbone of your ethics program. Your compliance team probably already has a strong relationship with your legal, finance, and auditing departments, but how well does it work with your human resources staff to train hiring managers to hire for integrity? How can you proactively influence ethics at every level of your organization? Partnering with HR is a cost-effective way to proactively influence the character of an entire company.

Promote Your Ethical Culture

An ethical culture starts with your executives. If your CEO demonstrates an attitude of achieving profit at any cost, an ethics initiative will fall on deaf ears. A solid tone at the top, a well-communicated code of conduct, and a publicly visible corporate ethics statement will build an ethical corporate brand.

Hiring managers across business lines should be trained to communicate the company’s ethical standards early in the hiring process. Incorporating ethics statements into job descriptions and including that information on all job postings, internally and externally, can aid in attracting job seekers with similar values to the organization.

Consider this: If your head of sales emphasizes compliant and ethical business practices early in the interview process, those candidates not willing to comply with high ethical standards may be dissuaded from pursuing the job. Human resources and the compliance team can work together to coordinate placement and delivery of the company’s ethical message to potential candidates for all open positions.

Ask the Right Questions

The highest executives are often screened for integrity, given the level of investment the company is making in the individual as well as the influence the new hire will have on the company. How can you ensure the same standards are carried through to the rest of your organization? Focusing primarily on the competencies needed to perform a specific job can lead to inadvertently neglecting other important characteristics.

Working together, compliance and HR can train hiring managers or others in the early screening process to ask questions that demonstrate a candidate’s character. This helps everyone understand why character is as important as competence and skill.

Questions that reveal integrity include:

  • When was the last time you had to make a tough ethical choice?
  • Describe a situation in which the pressure to compromise your integrity was the strongest you have ever felt.
  • Have you ever witnessed a colleague or supervisor acting in a manner you believed was unethical? How did you react?
  • Have you ever suffered a loss for doing what you thought was right? What were you willing to sacrifice?
  • Different countries and cultures have different standards for what they consider to be acceptable behavior. How should a global company’s ethics policy address these differences?

If any concerns are revealed during the interview, consider testing the candidate with an ethical scenario such as, “If our company ran into trouble, would you be willing to tell a lie for us?”

Be Diligent in Checking References

It’s surprising how often this step is neglected, particularly when hiring high-level executives. It may be taken for granted that a professional at such a high level would have a spotless background check, or the drive or pressure to fill the role may cause this step to be overlooked. In addition to the standard criminal and employment background check, follow up with references. Take notice of who the references are. Oftentimes the background of the reference and the relationship between the reference and the candidate reveal more than what the reference actually has to say. Look for high-quality references, including past managers or those well known in the industry.

See the Big Picture

Ethics is a crucial part of protecting your company’s reputation and bottom line. It’s a responsibility that extends far beyond a single department to every employee of the company.

To proactively reduce the risk of a “bad apple,” work with HR to train managers to hire employees who demonstrate unwavering character in the face of moral dilemmas. There’s no question that many employees will encounter an ethical challenge at some point, whether they’re an entry-level sales representative or second in command to the CEO. The real question is whether they will be prepared to handle it appropriately. The right training programs and the most thorough employee handbooks can only go so far. In the end, it all comes down to hiring the right employees—ones you can trust to act with integrity.

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