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Ethics and Compliance Programs: The Centerpiece of Trust

A Gallup Confidence in Institutions poll conducted June 2011 showed that fewer than one in five respondents have a “great deal” or “quite a lot” of confidence in big business (only Congress and health maintenance organizations fared worse out of the16 institutions included in the poll).

Treating Ethics as a Holistic Value to the Organization

Written by John M. Dionisio

A Gallup Confidence in Institutions poll conducted June 2011 showed that fewer than one in five respondents have a “great deal” or “quite a lot” of confidence in big business (only Congress and health maintenance organizations fared worse out of the 16 institutions included in the poll). While it’s true that in the nearly 40 years of Gallup’s survey, big business has never performed well, the trend has continued downward over the years and, since 2006, remains entrenched at or below 20%.

Certainly, on an individual basis many businesses can achieve high levels of the public’s trust.  Unfortunately, it only takes one bad actor among the business community to taint others – especially those who occupy the same industry as the perpetrator.  That’s why it’s not enough for each of our firms to only care about our own reputations; we are all connected, if not directly by the affairs of business, then certainly by the attitudes of the public.

As a result, besides our responsibilities to our respective stakeholders, all of us in the business community have an additional responsibility to each other in the ongoing effort to build and maintain public trust.  And, as we see from the Gallup poll trends, the need to go beyond the minimum in building trust is becoming more acute.  Here are three ways our team at AECOM is going beyond the minimum to make ethics and compliance a centerpiece in our trust-building efforts.

Treat ethics and integrity as part of a holistic organizational value system.  There is a tendency to treat ethics and compliance programs as the beat cop who’s keeping an eye on the neighborhood.  This creates the impression that these programs are designed to monitor for and punish errant behavior, when instead we want to educate about and encourage the right behaviors.

Ethics and integrity should be an organic byproduct of the organizational culture and the values that underpin corporate reputation and the brand.  AECOM’s purpose statement, to create, enhance and sustain the world’s built, social and natural environments, is more than the way we pursue business, it informs our commitment to conduct ourselves as sound corporate citizens.

Just as our philanthropic programs and pro bono volunteer services for organizations such as Engineers Without Borders, Water For People and Habitat for Humanity affirm our commitment to communities in need, our ethics and compliance program affirms our commitment to earning the trust of our stakeholders.

Institute strong governance, enabled through visible leadership.  As with many public companies, ethics and compliance governance resides at the highest level of AECOM as part of the charter of the Nominating, Governance and Risk Committee of the company’s Board of Directors.  In addition, AECOM has a separate internal ethics and compliance steering committee, consisting of senior leaders across our global operations to review the status of the program and any matters that require attention.

Complementing our formal ethics and compliance governance, our recently formed Global Advisory Board, chaired by former United Kingdom Prime Minister Sir John Major, provides deeply knowledgeable counsel and guidance to help us more fully understand and anticipate the economic, political and social impacts of our business strategy as well as potential challenges that could affect our stakeholder relationships and overall reputation.  The insights we gain from the members measurably improve our global and cultural awareness and overall moral perspective.

While an ethics and compliance governance framework establishes the intent to operate with integrity, visible and engaged leadership demonstrates the organizational commitment to do so.   All of AECOM’s geographic leaders directly communicate their support for the company’s ethics and compliance program, including through messaging that accounts for cultural and language differences.  These communications reinforce my own views on integrity, which are regularly delivered through videos, face-to-face engagements and emails to our employees around the world.

I also look for opportunities to underscore our commitment to integrity with external audiences.    To that end, I was pleased to participate in a panel sponsored by Ethisphere at the New York Stock Exchange last September to discuss the traits of ethical leaders.

Elevate the organizational consciousness to act with integrity.  We have implemented many of the standard actions to boost ethics and compliance knowledge, including the requirement that all employees read and certify their understanding and conformance with AECOM’s Code of Conduct (available in 12 languages); the availability of an ethics hotline through which employees can anonymously report suspected unethical behavior; and access to online training vignettes and relevant news and information through our dedicated internal ethics and compliance portal.

But we have taken a few more steps to elevate integrity as the most important of AECOM’s core values.   Last September, we inaugurated a Global Ethics Week, which included events across our operations to emphasize and reiterate our commitment to ethics and compliance – including a video of employees throughout the world expressing their thoughts about the importance of acting with integrity.

We also conducted a webinar featuring Keith Darcy, executive director, Ethics and Compliance Officers Association, who shared his insights on managing ethics and compliance in the age of social media.  And, we established an Integrity Award as part of the company’s annual Excellence Awards to recognize and honor employees who demonstrate superior commitment to this critical core value.

By taking these additional measures, we give our employees more opportunities to examine and constructively engage leadership and colleagues about ethics-related matters. In fact, our most recent employee survey indicated that 80% of responding employees rated ethics and compliance as a strength of AECOM – the highest score among 19 categories surveyed.

Ultimately, AECOM’s reputation for ethics and integrity is a proxy of the trust we have earned as an organization.  Like any corporate asset, trust accumulates or diminishes based on how we manage it.  Since trust is the capital that underpins reputation, we will continue spending a good amount of time trying to ensure that the net asset value of trust is growing in line with the ambitions of the enterprise.  The good news is that we have the ability to increase trust every day, across all of our stakeholder engagements, and we remain committed to that effort.

About the Author: John Dionisio is Chairman and Chief Executive Officer of AECOM Technology Corp.

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