“How Effective Is Your Ethics Training Program?”: Lessons Learned

Participants in this September 27, 2011 workshop in Ottawa heard first from keynote speaker Dr. Michael Hoffman. World-renowned academic Professor Hoffman is the founding Executive Director of the Centre for Business Ethics at Bentley University in Massachusetts and has written or edited 16 books and 95 articles on the topic of ethical practices in organizations. He is also a founding member of the Ethics Officer Association, now the Ethics and Compliance Officer Association (ECOA). Dr. Hoffman recently received the Society for Business Ethics Lifetime Achievement Award for Distinguished Service. Dr. Hoffman shared with participants the key components of an effective ethics training program.
Following Dr. Hoffman’s presentation, participants broke into small groups to discuss a series of key questions. Each table discussed one of four major questions and noted the key lessons drawn from the presentation as well as from the practical experiences of participants. We are pleased to share the results from the tables received to date:

Question 1. What are the critical elements of an effective training program?

Table 1 reply:

1. Effective communication to staff about training
2. Consultation with various groups on training
3. Buy-in from senior management (and board)
4. Tools, devices, scripts that ensure common message (e.g. relevant vignettes, dialogue)
5. The ethical maturity model of Dr. Hoffman, namely from ethical awareness to reasoning to action to leadership

Question 2. How do we create an effective training program when resources are limited and yet we must cater to different groups and levels of people in an organization? 

Table 2 reply:

Approach 1:

• Create an ethical climate survey to determine where the “hot spots” are, prepare an action plan to address and develop plan for continued renewal. Focus on priorities based on “hot spots” identified as:
  • Leadership
  • Training
  • Communication
• Have the program applied to all employees equally so that discussion can occur at all levels simultaneously and provide supervisors and managers additional help and support. Benefit: allows employees at all levels to see different types of situations as senior managers may not be aware of what is happening at more junior levels, and vice versa
• Have developed application guide which includes scenarios and has been well received
• Have completed an ethical climate survey within the department based on what CSC has produced

Approach 2:

• Short term: Use a multi-pronged approach.
  • Supervisors and managers receive comprehensive training in values and ethics, tools, resources, information and skill building support on ethical dialogue, decision making, decision making models, etc.
  • Approach could be train the trainer with supervisor/ manager
  • Provide all employees with general awareness sessions about their role, responsibilities and general information about values and ethics
  • Objective: provide supervisors and managers with the skills necessary to lead change within their units and have the skills to address values and ethics
• Medium term:
  • Once majority of supervisors and managers are trained and have the skills then start providing the same skills building training to employees to help them move beyond just general awareness of values and ethics
  • Objective: bring employees up to the same skill set as supervisors and managers and start getting more ethical dialogue happening

Approach 3:

• Integrate V&E into all existing programs because operational requirements do not permit for stand alone V&E courses of training, and therefore this infusion is most effective
• Looking to extend on concept of ethical dialogue
• Have implemented a scenario’s discussion and voting system whereby a scenario is presented, discussed and then a course of action is voted on
  • Votes confidential
  • Results of the vote discussed as a group to seek out dialogue on feelings, reactions, general discussion

Additional Resources:
DND has a great website with lots of information and tools which PCO is using to supplement their tool box

Table 6 reply:

1. A one-size-fits-all training program isn’t generally considered the most effective, although it may be done that way for the initial training on the code, values and program in general, if resources are tight. In such cases, in order for ethics training to be really effective, the initial training should be followed by tailored sessions that address the specific issues and take into account the culture of different sub-groups in the organization.
2. Online training can be considered for initial ethics training purposes, namely for cost efficiency, time or accessibility (regions) reasons, but it needs to be truly interactive. New technologies open up avenues to this effect that might be considered.
3. Since resources are limited, choices must be made as to which groups/individuals should be targeted first, or most, for training. Middle managers are seen as the most important group to target. Ethics training for managers should aim not only to develop knowledge of the code and values and ethical awareness, but also develop the necessary abilities to effectively manage and encourage ethics.
4. We encourage the development of a diversity of tools regarding ethics in the organization. A guide and toolkit for managers is one such tool, providing guidance on ethical leadership, the organization’s values and the interpretation of its code, and ways to discuss ethics with their employees. This way ethics can stay “alive” in the organization. In addition, if resources are insufficient to provide formal ethics training to all, managers can provide some basic training to their employees on their own.
5. Ethical decision making skills are a necessary part of ethical training. Use of an ethical decision making model is recommended. The model is also a tool that should be widely communicated across the organization.
6. When resources are limited, partnering with other services could be considered. Integrating the enhancement of certain more general abilities related to ethics, such as communication or leadership skills, as an element of other organizational training, in order to spread the costs, could also be considered. Training partnerships might also be considered with outside organizations of similar nature in the case of very small organizations.

Question 3. How do you evaluate the effectiveness of your ethics training program?
 
Table 7 reply: 

1. Foundations and infrastructure are needed to build an effective ethics program. The ethics training program is one part of that overall ethics program.
2. Buy-in is required from all levels.
3. Besides the methodology difficulties in measuring the effectiveness of ethics training, the current fiscal environment does not allow most organizations, public or private, to dedicate the financial and human resources required to truly track and analyze ethics programs and their effectiveness.
4. Measurement of effectiveness begins with deciding on scope: is it the ethics training program or the overall ethics program that is to be examined? If the training program, then the measurement should relate to the training objectives: basic awareness, which is quite simple to check, or other objectives such as comprehension?
5. Case studies can serve evaluation as well as training purposes because people’s level of awareness and their capacity for ethical reasoning become evident in their discussion of the cases.
6. There is an absolute requirement for a “top down” sanctioning of ethics training programs, while concurrently having all levels of the organization demonstrate ethical leadership. Thus two senses of ‘leadership’ should be addressed in looking at the effectiveness of the ethics program. On the one hand, are those in formal leadership positions (executives, senior managers etc) meeting the expectations that are particular to those offices? (These include establishing and sustaining the overall ethics program, modeling desired ethical behaviour and visibly rewarding such behaviour.) On the other hand, to what extent is informal ethical leadership practiced throughout the organization by persons in any position at any level? (This happens when individuals behave ethically and show others how to do it.)
7. There is difficulty in establishing a “safe place” for employees to refer to with ethical problems / dilemmas, given that the ethics and compliance offices are generally a corporate creation that is overseen by management, who may be the problem.

Question 4. How does one know that the ethics training delivered has had the desired impact on the organization’s culture/ the behaviours of employees?
 
Table 4 reply:

1. Identify the impact you are looking for vis-à-vis your ethics program:
   1. identify the drivers for establishing programs, e.g. enhancing trust of public in agency’s staff and programs
   2. establish a baseline
2. Use employee surveys judiciously bearing in mind survey fatigue, introduction of negative bias, voluntary nature of participation
3. Having identified processes and programs at risk (e.g. staffing, procurement, grants and contributions), work will then be to ensure values and ethics influence/presence, and identify problems
4. Build values and ethics into staffing, screening, internal promotion, performance evaluation: seek data from human resources unit on trends
5. Identify measurable indicators such as number of queries, conflict of interest reports, complaints, number of discussions, etc. and analyze trends
6. Work with audit and evaluation unit to influence audit and evaluation planning, long-term and annual, to get information on indicators of unethical practice, e.g. in procurement
7. Evaluate training programs not only immediately but long-term (6, 12, 18 months). Include knowledge, culture, attitude
8. Obtain external public and stakeholder data:
   1. Public opinion polls done regularly on trust, such as those done by EKOS
   2. Organization’s public opinion research
   3. Talk to suppliers, clients, contractors

Table 8 reply: 

1. Organizational Culture: Senior management sets the tone for a values and ethics’ culture within an organization through leading by example.
2. Values and ethics training: Training needs to be relevant to participants i.e. their present context.
   • One way to ensure this is to solicit case studies from employees in order to enhance participant’s engagement and avoid training fatigue and/or complacency.
   • Training needs to recognize that there are different organizational cultures that raise different V & E questions, thus in going beyond orientation/awareness training, “cookie cutter” approaches are limited in their impact. E.g. Questions raised in a scientific culture are different from a finance culture; new employees have different questions than experienced ones; management has unique challenges quite different from non-management issues.
3. Indicators that speak to a positive V & E cultural shift in organizations include:
   • The level of comfort employees have in discussing uncomfortable “undiscussables” with superiors. (Can be determined through surveys.)
   • A shift in the nature of the questions being raised in V & E environments from that of basic awareness (i.e. what is a V & E program?) to questions that seek guidance. This indicates a shift from ethical awareness to ethical engagement.
   • Other indicators includes positive health & safety records; employees have a high level of satisfaction in their jobs; low incidence of stress leave.
   •  Indicators should go beyond mere counting to include antedoctal indicators such as stories that answer the question, “What & why is it working?”
4. Celebrate success: When a V & E crisis is averted, often no one hears of it (i.e. bad news spreads faster) therefore success should be acknowledged and celebrated within the organization (or team) that dealt with the matter.

Additional material on Question 2 (provided by Table 2):

How do we create an effective training program when resources are limited and yet we must cater to different groups and levels of people in an organization?

• Mixed groups containing all levels from employees to executives
  • Sometimes it works, sometimes not
  • Need to create optimal learning environment where:
    • Balance safety and integrity
    • Develop an emotional connection
    • Create a safe space (discussion on how to achieve this)
    • How to address gaps between formal and informal culture
• How do you recognize/ reconcile personal and corporate beliefs?
• In the scenario, corporate values are one thing and these are communicated well but what happens when the informal values continue to exist but:
  • Are not acknowledged
  • Messaging is that we keep same values (i.e.: same values, new program) = mixed messages
  • Incompatibility between corporate values and informal values
• Values and ethics are a tremendous opportunity – an opportunity to explore creativity, productivity, and new ways of doing things. It can be used as a positive force, and leveraged to motivate, stimulate and renew how things are done and what we seek to accomplish. Examine soft measures such as productivity, engagement, turn over rates within the context of setting values and ethics. Need to continue to find ways to inspire people rather than using V&E as a problem solving framework.
• What tools are appropriate for ethics training?
  • Awareness can be done online (varied opinions on this)
  • Anything about awareness (i.e.: dialogue, reasoning, action, leadership) requires an interactive forum where discussion can happen
• Ideas for leaders: pick up a scenario and bring it to staff or team meeting to discuss the scenario.
• The use of 360 degree evaluations to gain self-awareness which can contribute to a learning approach
  • Need to be conducted from the highest levels first and then rolled down
  • Home depot has a good 360 degree evaluation program (multi-year improvement initiative)
    • Year 1 – 360 degree evaluation – only employee knows the results
    • Year 2 – employee and coach are made aware of results
    • Year 3 – employee, coach and HR are made aware of results
    • Year 4 – employee, coach, HR and supervisor are made aware
    • Program works on the assumption that with time the employee will learn more and more about themselves and the work, and seek development, change and improvement
• Do we need ethics training as is? Or can it be integrated into other training?
  •  i.e.: new employee training, leaders training, etc.