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Speak-up culture toolkit: Policy management

Supercharge your employee engagement by pairing effective policy management strategies with a fortified speak-up culture

Noshin Kahn
Senior Compliance Counsel, OneTrust
February 20, 2023

Photo looking down large industrial warehouse aisle with boxes on tall shelves

In the challenging area of ethics and compliance, companies can bolster a speak-up culture and drive better outcomes with clearly written policies, training, and ongoing assessments of policy effectiveness. Built on trust, a speak-up culture strengthens legal compliance, increases job satisfaction and productivity, while helping the organization manage and mitigate many forms of risk.

Once employees clearly understand the reasoning behind policies such as conflict of interest, bribery and corruption, gifts and hospitality, whistleblowing, etc., they are more likely to feel comfortable speaking up – knowledge builds confidence. Companies can take this one step further by providing psychologically safe environments for employees. Fear and uncertainty decline and doing the right thing becomes the norm. 

While it’s one thing to talk about improving the culture via policies, it’s quite another matter to create, implement, monitor, measure, and improve such policies over time. Many complexities come into play – from the specific requirements of regulations to employee reluctance to serve as whistleblowers, to the fact that many organizations don’t even have systems and procedures to track attestations of policies with metrics. 

These issues raise many questions. What kinds of policies are needed – and what’s the best way to manage them? How will those policies change and improve the organizational culture? How can employees best be engaged to feel comfortable about following policies that increase disclosure rates, reports of violations, and transparency, and accelerate problem resolution?  

To answer these and related questions, let’s consider some of the most common issues organizations face today when creating and implementing effective policies that lead to more ethical workplaces.

Want to learn how to raise awareness for your helpline and overcome reporting reluctance? Download our How to Build a Speak-Up Culture eBook today.

What types of policies can help build speak-up culture? 

Organizations must consider how employees engage with policies and procedures in order to properly structure those materials, drive employee engagement and increase disclosure rates. When developing policies that set the standards and expectations for employee conduct, keep several factors in mind to fortify a strong speak-up culture. 

Overall, message clarity must be the top priority. Use clear and easy to understand language that communicates why adherence to policies is so important. Then, make sure employees have easy access to stored documents and can locate them at a moment’s notice. Doing so will help convey company transparency and encourage employee engagement. 

Use the following tips to help you get started on developing effective policies:

Reflect company values and ethics 

To help clarify employee expectations, structure policies that address laws and regulations while simultaneously making a connection with the organization’s core values. 

Incorporate employee input and designate individual stakeholders 

To help build trust through collaboration and individual input, establish a policy development team with a range of stakeholders including HR, legal, executive management, supervisors, and employees. Assign policies to specific stakeholders to incorporate the necessary oversight for key areas of the company.

Use language that permits management discretion  

Avoid black and white statements that do not consider the potential for mitigating circumstances. Instead, use policy language that allows for more understanding and context while maintaining alignment with laws and regulations.

Balance flexibility with disciplinary action 

Include a statement in your company policy manual introduction outlining the general rules around disciplinary action. Make it clear there is no one-size-fits-all approach to disciplinary action given the complexity and semantics of each incident or violation.

Applying these tips and others will help you establish effective policies that encourage a speak-up culture. 

How to get employees to engage with policies?

Once you have finalized your policies, conduct thorough training on each policy. Communicate the risks and stress the importance of policy compliance, reporting violations, and making disclosures. Establish accountability by explaining why following company policies and any applicable local or international laws is every employee’s responsibility. 

Integrating active participation is more likely to keep employees alert as they learn, while reinforcing the importance of the training. Fast-forwarding to the end of a training module and checking a box is no longer an option. 

A visual approach can make a greater impact. Show employees the entire process, from the moment a report is submitted, to the mitigation and closing of the report. When employees are satisfied that the organization will take disclosures and violation reports seriously and thoroughly investigate them, the disclosures and violations reporting rates will naturally increase. 

Codes of conduct with clickable content and Q&A sessions are also effective training methods. Online quizzes or in-person workshops with interactive games can help ensure policy comprehension. These activities will generate data that, when analyzed, will reveal opportunities for improvement.

To help ensure ongoing compliance, maintain regular communications with employees via emails, intranet, in-person visits to offices, or ethics and compliance office hours.  

How to enforce policies in a way that builds psychological safety and strengthens your speak-up culture

In psychologically safe environments, there’s a shared belief that co-workers or management can make disclosures and report policy violations without fear of repercussion. Also, psychological safety helps create a sense of empowerment. If psychological safety is lacking, employees keep quiet even when it seems clear that speaking up is the right thing to do. For example, when it comes to policy management, if employees feel the risk of making a disclosure or reporting a violation is too high, they will remain silent. 

Whether working remotely or in hybrid work scenarios, you can nurture psychological safety by taking one or more of the following actions: 

  • Foster a culture that respects different opinions. 
  • Be intentional about scheduling one-on-one meetings. 
  • Ask open-ended questions. 
  • Demonstrate how to establish boundaries. 
  • Set expectations for in-person and video meetings. 
  • Avoid blame. 
  • Be available to answer questions and address concerns.

Cultivating a psychologically safe environment increases team members’ confidence in speaking up, making space for them to question the behavior and decisions of others, while exposing questionable practices.  

How do you know your policies are working?

The final step in an effective policy management process is to evaluate the level of success at each stage of the lifecycle. Policy management on a digital platform empowers companies to easily retrieve metrics that will help them assess employee knowledge, engagement, and compliance. 

Ask some or all these questions as part of your assessment:

  • What percentage of employees completed a training session? 
  • What percentage of employees passed the training tests? 
  • What were the average test scores? 
  • What percentage of policy attestations have been completed? 
  • Are there any gaps in the training curriculum? 
  • How many disclosures and policy violations have been reported since the policy effective date? 
  • Has reporting frequency increased or decreased for disclosures and violations? 

The metrics retrieved from the system will provide insight into how to refine your policy management process and reveal opportunities for training and communication improvement. Consider sharing certain impactful data points with employees to showcase increased levels of policy compliance, engagement, and reporting.

Over time, as disclosures increase and violation reports decline, an organization can confidently say that their employees are informed and accountable. A solid speak-up culture will reveal how confident employees are in speaking up and their trust in the organization’s integrity when addressing issues.  

For more information on policy management and the power of a speak-up culture, download our speak-up culture e-book for a step-by-step guide on raising awareness of your company policies and improving disclosure and reporting rates.


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