The health of your speak-up culture is paramount. For proof, look no further than the 2022 Honoree List for The World’s Most Ethical Companies. For a company to become an honoree, an organization is assessed and measured across their governance, leadership and reputation, ethics and compliance program, culture of ethics, and environmental and societal impact. Becoming an honoree depends on both qualitative and qualitative measures, painting a complete picture of your company’s ethical health. If your organization ever wants to join this elite list of global changemakers, the health of your speak-up culture is paramount.
By utilizing both quantitative and qualitative measures, just like the World’s Most Ethical Companies, you can measure the health and vitality of your speak-up culture. Keep reading for specific questions to ask, metrics to measure, and more.
Read Between the Metrics: Beware Low Speak-Up Volume
Before we embark on the quantitative and qualitative measurements of your speak-up culture, we should stress the need for using both. Without the holistic view that comes from qualitative measurements, the numbers will only tell one part of the whole story. For example, if the volume of reports coming into your speak-up channels is low, you might celebrate it as a victory. But before you pat yourself on the back, remember that low report volume can be linked to reporter anxiety and mistrust of your speak-up program.
However, even the gaps in your data can tell you something. For example, do you receive more anonymous reports from your online speak-up channels than you do proxy reports (in-person reports submitted to a manager)? Perhaps trust in your speak-up program is high, while trust between teams or between levels in the organization is low. The same applies when you see abnormally low speak-up volume within certain departments or locations.
When building a culture of compliance and a strong speak-up culture, the emphasis should not just be on the outcome, but rather on both outcomes and the processes that contributed to the outcome. Although there isn’t a one-size-fits-all prescription here, we recommend identifying both your hot spots (where the data shows higher-than-average incidence of infractions) and blind spots (where your data is suspiciously sparse). Whether you’re collecting responses in an annual ethics survey or conducting focus groups, your data will help steer you in the right direction.
Take a Tip From the DOJ and Ask These Five Questions
Remember those giant test prep books for the SAT? When you know how the test will be structured, what the content of the exam will be, and what knowledge will be tested, you can prepare strategically and not waste any precious time. While we’re happy the SATs are behind us, the importance of intentional preparation isn’t wasted on us as Ethics and Compliance professionals now. In June of 2020, the U.S. Department of Justice Criminal Division updated their Evaluation of Corporate Compliance Programs guidelines. Although these guidelines are targeted towards corporate compliance programs in general, they will help you understand the expectations for a compliant program and, as a result, a healthy speak-up culture.
This DOJ update emphasizes five questions that can guide your Speak-Up Culture KPIs:
- Is the organization’s compliance program—and by extension, your speak-up program—well-designed?
- Is the program being applied earnestly and in good faith, e.g. is it being implemented effectively? In other words, do you provide speak-up channels as a check-the-box item without further awareness and engagement activity, or do you ensure that the speak-up channels are user-friendly and accessible?
- Does the program work in practice? Use your reporting volume as a health check.
- Have the policies and procedures been published in a searchable format for easy reference? Do potential reporters know where to find your speak-up channels?
- Does the company track access to various policies and procedures to understand what policies are attracting more attention from relevant employees? Are you measuring traffic to pages where your speak-up channels are featured?
An ethics and compliance Insights tool consolidates trackable KPIs into a centralized dashboard, helping you in your quantitative data analysis. Remember that your numbers and stats don’t exist in a vacuum, so tracking important data at regular intervals will be more valuable than a single data point within a silo, frozen in time and devoid of context. Measuring trends in your data will help gauge the successes and failures of your compliance program. Having a grasp on trends, and comparing where you are now versus where you started, is far more valuable than knowing where a number stands at a single point in time.
Quantitative Measurement Recommendations
- Number of times and how often your speak-up pages are reviewed and/or updated
- Number & nature of speak-up reports
- Culture surveys & knowledge assessments results
- Training reach, medium, frequency & completion rates
- Reach, medium, frequency & engagement rates of compliance communications
- Training program update rates
- Post-training test results
- Number and nature of incidents by employees who have completed training
- Reporting rates, known and anonymous/1000 employees by reporting channel
- Retaliation report trends, including the number of reports of retaliation
Now that you’ve got an accurate set of quantitative measurements, it is time to pivot over to the qualitative side of things—in other words, add context and color to the numbers by speaking to the people behind them. This is an excellent opportunity to get a more holistic view of your speak-up culture’s health. During your listening sessions, you can drill down into the “why” behind your data.
Sources for Qualitative Measurements
- One-on-one meetings
- Q&A forums
- Focus groups
- Anonymous online reviews (positive and negative)
- Company and leadership reputation (internal and external)
Depending on what you uncovered during your quantitative analysis, you may know exactly where you need answers. But if you’re unsure where to start, we recommend getting a baseline temperature check on organizational trust and buy-in, asking if your employees believe you’re indeed taking your own medicine. Ask your leaders and entry level employees alike if they feel like their psychological safety is respected and championed. By asking open-ended questions regarding issues like trust, transparency, and consistency at your organization, you may uncover more nuanced answers that might have been overlooked by the quantitative analysis.
Remember that by asking these questions, you’re embarking on an emotional journey with your subject/s. Make regular listening sessions a priority to demonstrate your organizational commitment to feedback and to dilute the potential emotional impact of ad hoc venting sessions. Set the expectation that rules of engagement will be respected and sensitive subjects will be approached with care.
The ethical health of your organization doesn’t live in a vacuum; it lives in the speak-up culture data you collect over time and the behavior you model every day. Through utilizing both quantitative and qualitative measurements, you can identify areas for improvement and spaces where you can celebrate successful culture building. By tailoring your speak-up culture metrics towards compliance with DOJ guidelines, you’re not only building a solid foundation, but preparing to prove your commitment to a healthy speak-up culture. Embrace the importance of a robust speak-up culture, go the extra mile to collect accurate data, and maybe one day your organization can join the ranks of the world’s most ethical. You’ll be in good company.
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