By Jean-Pierre Méan
Published on Tuesday January 8, 2019
There is a wide consensus amongst all those involved in compliance and anti-bribery that the success of an integrity program requires an unflinching commitment at the highest levels of the organization, aka tone from the top, leadership or walking the talk. But what does this commitment consist of and how does it express itself?
The launch of an anti-bribery program is often accompanied by a statement expressing support for the program by the Board and Top Management. This statement, signed by the Chairman and the CEO, is intended to be distributed to all personnel together with the anti-bribery policy or Code of conduct and is published on the organization’s internet site.
This is a first step towards demonstrating leadership. However, it could also be a mere communication artifice without real substance.
Establishing the tone from above will therefore also require interviews with the Chairman or Board members as well as with the CEO and other member of Top Management and of personnel. Hearing these individuals discuss integrity will provide a pretty good indication of how serious they are about their organization’s professed policy and how their commitment has transpired throughout the organization.
However, some individuals are very good at feigning convictions that they do not really hold. A famous instance of this is a statement by Ken Lay, Enron’s CEO, about how important integrity was at Enron, at a time that he must have known about the irregularities that led to Enron’s bankruptcy.
The tone from the top, when it is sincere and profound, will leave its mark on all those working under a committed leadership. It will be transmitted less by words than by example.
Here is an anecdote to illustrate this in a simple way. One day I had difficulties opening my mailbox and thought that the lock was broken. I then walked a couple of blocks away to a locksmith who offered to come with me to fix it. When he looked at it, it turned out that it was not broken at all but that I just had not been very good at opening it. I thanked him and offered to pay him something for his time. He firmly refused, saying that he had not done any work, but suggested that I should occasionally go by his shop and leave something with the receptionist who was keeping some cash for special occasions.
I did as he recommended, but as soon as I made my offer, the receptionist refused to accept anything just as firmly as her boss had. Her boss had obviously told her what had happened and she must have found that he did the right thing by refusing to be paid for work he did not do and that there was no reason why she should not act in the same way. In other words, the receptionist was sufficiently impressed by her boss’s example to decide on her own to follow it even though her boss had suggested otherwise. This, I guess, is tone from the top at work.
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