A. Develop an applicable standards and procedures section that includes four elements of acceptable or unacceptable behavior found in a code of ethics.
1.Integrity- We will always do what we say and say what we do. We must always be consistent, credible and act with integrity. Employee’s actions should maintain high integrity in all activity related to this organization. 2.Diversity- Our culture is based on mutual respect and we value the differences that each employee brings to their position. Employees will treat others with respect and should build an environment of mutual respect. Employee differences and disagreements should always be handled peacefully and professionally. Employees will respect cultural and racial differences and work support an environment where all employees are respected for their contributions.
3.Open Communication- If you have questions, concerns or complaints, you are encouraged to talk to your manager. We value you as an employee and want to ensure that each employee’s working environment is pleasant, productive and that your feedback is heard and acted upon. Should you prefer to speak to someone other than your manager, you can contact your Ombudsman at any time. 4.Accountability- Employees will take accountability for their actions and contributions to the business and should hold each other accountable for maintaining ethical behavior that is in line with our code of ethics.
B. Develop a section that identifies at least three specific elements for an ethics training program.
Ethics Training Program
1.Departmental Training- We require all departments to provide regular training to ensure understanding and awareness of corporate standards related to ethical decision making. Training should be focused on employee awareness of ethical standards and understanding and use of resources for employees. These departmental training sessions will be manager or peer led sessions and will be done on a quarterly basis. 2.Annual Company Wide Training- We will require annual ethics training and certification for all employees. The training is required to be completed annually and will be mandatory to all employees. Manager bonus programs will be dependent on department/team participation. 3.Managerial Training- Managers will be required to be certified annually to show understanding and alignment with our existing ethics programs and any ongoing changes to the program.
C. Develop a section that explains the processes for each of the following:
1. Monitoring employee misconduct
2. Auditing employee misconduct
3. Reporting employee misconduct
Managers will be required to monitor employee conduct in several ways, including regular interaction, performance reviews and evaluation of quarterly surveys. Regular interaction with the team will ensure that managers are engaged in the over-sight of their department and able to interact and coach employees before issues escalate. Quarterly survey results will be used monitor employee conduct and behavior. These surveys will help to identify possible team issues and allow employees to share anonymous feedback on a regular basis. Surveys also give the employees the ability provide feedback on the department, manager or any issues that may be taking place as well as to leverage or engage human resources. Performance reviews will be used to coach through behavioral issues, including ethical issues as well as to monitor the professional growth, contribution and alignment with corporate and ethical goals.
Executives will oversee the managers and will work to identify issues/conflict in their department through quarterly skip level interviews, anonymous reporting options, and access to cross segment feedback on individuals. Both Managers and Executives will be supported by corporate HR which will also have visibility and oversight into the employee feedback shared through various anonymous feedback sources. The Human resource department should constantly look for early signs of ethical conflict with corporate standards with the goal of supporting a healthy environment. Both the HR department and the executive team shall have cross segment visibility and oversight into employee behavior with the goal of identifying risks to the corporate culture and standards.
Auditing Employee Conduct
Employee conduct will be audited via several means including but not limited to surveys, coaching, web training, employee performance reviews and anonymous reporting options. This will ensure corporate visibility and oversight into the adherence of employees to our ethical standards. These mechanisms will have a weighted score attached to the result as follows:
•Quarterly Survey’s 15%
•Managerial Coaching 30%
•Web Training 15%
•Employee performance review 30%
•Anonymous reporting results 10%
Web training and surveys will be tailored to gather specific data based on corporate priorities at the time of these actions. Managerial coaching sessions, employee performance reviews, and anonymous reporting will be used to audit employee support and adherence to our ethics program. Audit scoring will be on a 1 to10 point scale. The Human Resource department will compile the results and produce an enterprise wide report which shall be released quarterly.
Departments that do not meet the standard of 90% or higher will need to create a plan of action. Managers, directors, and a representative of human resource will create a plan of action along with a timeline for remediation and this will be managed by the HR department. In addition, an outside auditor must review the ethics program annually to confirm that ethical standards are being followed and maintained as expected.
Reporting Employee Misconduct
All employees will have access to a corporate website, toll free phone number and an ombudsman that employees should use to report misconduct or violations of the corporate ethics policy. In addition, managers may use all other corporate communication tools such as email, instant messenger or phone conversations to gain visibility to and to report misconduct.
D. Develop a section that explains your plan to do the following: 1. Evaluate the effectiveness of the ethics program after implementation. 2. Provide suggestions to improve the ethics program after implementation.
Ongoing Evaluation of our Ethics program
During our annual third party audit, the auditing company will review the overall effectiveness of our ethics program to show annual performance trending from the previous year as well as a comparison to industry results. Upon completion of the third party evaluation, we will use the information to identify strengths and opportunities in our corporate ethics program which will be used to build the following years plan metrics and priorities.
Ongoing Improvement of our Ethics Program
We are a pay for performance organization and as such, Executive bonus plans will be tied to successful achievement of our corporate, ethical standards. Ten to thirty percent of Executive bonus plans will be paid at a multiplier of (2X) as long as the third party assessment shows 90% or greater achievement of corporate ethics targets. In addition, we will provide company wide, quarterly reports to share our performance with the employees and we will adjust key manager incentives to ensure alignment of departmental ethics goals to company goals.