1. Compliance & Ethics
Professional
®
a publication of the society of corporate compliance and ethics www.corporatecompliance.org
January
2016
Meet Kasey Ingram
General Counsel Chief Compliance Officer,
ISK Americas Incorporated
in Concord, OH
See page 14
37
The role of the
data protection
officer in Europe
Robert Bond
33
Compliance in
Spain: The other
way around
Ricardo Seoane
27
Unwrapping your
gift policy: Love
what’s inside
Cynthia Scavelli
31
A sense of
compliance in
the workplace
Laura Serra Nova
This article, published in Compliance Ethics Professional, appears here with permission from the Society of Corporate Compliance Ethics. Call SCCE at +1 952 933 4977 or 888 277 4977 with reprint requests.

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ComplianceEthicsProfessional®
January2016
by Frank Bucaro
F
or the past three decades, I’ve been
crisscrossing the country speaking
to large and small businesses and
organizations on ethics and values. The vast
majority of my audiences agree that embracing
ethical behavior just makes good business
sense. In fact, I can hardly think of
more than one person who has ever
disagreed with that premise. So after
three decades with ethical problems
still making headlines, I began to
wonder, then, what’s the problem?
My answer is twofold:
failed leadership and the lack of
moral awareness.
Failed leadership
Failed leadership is not about leadership
skill sets or how many degrees one has, one’s
title or position. Failed leadership is about
the lack of commitment, empowerment, and
transparency in the individual and therefore, in
the organization.
The Skout Group, LLC, is a nationally
known ethics resource company, and in their
research case study, Getting Beyond the Numbers:
How to Identify the Root Cause of Unethical Conduct,
here’s what they conclude, “The heart of most
unethical conduct, as well as lack of reporting
violations, can be attributed to workers who
feel alienated and disengaged. These negative
attitudes crop up when employees can’t see or
live their personal values in the workplace.”1
Why haven’t leaders recognized this? What
are leaders doing about employees who feel
alienated and disengaged? This opens up a
variety of compliance and ethics issues in and
of itself.
Commitments are something that one
needs to work on continually. This needs to be
a concentrated focus of your ethics training,
discussions on values of the organization, and
how to implement and live out that commitment
in the everyday course of doing business.
The biggest ethical leadership challenges
today, in my experience and research, are:
·· Doing business day-to-day. That includes
what are the long-term interests of
customers, not just the short-term interests
of the company;
·· Doing the right thing. If we were to expand
that just a little bit more, doing the right
thing at the right time for the right reason is
good business today; and
True leadership faces a
serious moral problem
»» The “cost” of failed leadership and lack of moral awareness is measured not just in monetary terms, but in morale and
productivity as well.
»» One’s personal values must be in alignment with their corporate values, and training is needed to help in that alignment.
»» Techniques and insights that are explained can be used immediately to be more proactive in dealing with these issues.
»» The reality is that to do nothing is a decision, and for each decision, there is a price to pay.
»» Values-based leadership development is the most proactive approach to forestall these issues from becoming major issues.
Bucaro

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·· Being careful about what we ask others to
do, because they listen with their eyes. If we
ask someone to do something that we’re not
willing to do or find distasteful, etc., what
is that saying to those who work with us
and for us? Be careful about what we ask
others to do.
Leaders need to be discerning as to the cause
and effect of decision-making now more than
ever before, because as mentioned, people listen
with eyes, not with their ears!
Lack of moral awareness
What about moral awareness? Here’s one of
the best definition of moral awareness that I
received from a client of mine:
When a person is in touch with their innate
sense of morality and can feel the moral
component of the situation—one of my
clients that helped me with this definition
said it’s kind of like being in touch with your
body. If you know that there’s something
wrong, there’s a pain. It’s an innate sense
that there is something wrong; it needs to
be attended to. That’s what being morally
aware means. There’s something, you know,
about what you feel, about your reaction to a
situation that says that something’s not right
here. You can call it intuition, you can call it
conscience, you can call it reason, whatever
you want to call it, it’s an innate sense that,
something isn’t right here and I have to
figure out what to do about it.
Therefore, there really are moral
obligations, particularly for leaders.
Always put people first in decision-making
In a recent research paper that I read, it
said that 57% of all companies that have
downsized in the last few years still have the
same problems, which tells me that it wasn’t
an employee problem, but that they were the
ones made to pay a price for the problem of the
organization. Maybe it was the process, maybe
it was the leaders, maybe it was whatever, but
people need to be first in decision-making,
particularly in the long term, because no matter
what organization or business, they all say,
“People are our most important assets.” Then
why aren’t people a priority in many areas of
decision-making?
Respect the individual human dignity
You have a right as a leader to disagree with
my behavior; you do not have the right to
challenge my human dignity or my self-esteem.
There is a difference between telling someone,
“You are the dumbest thing next to the
jackass,” as opposed to, “Normally you don’t
make decisions this poorly. I was wondering
why this decision was made and how you came
to that?” See the difference? Remember, affirm
personhood, disagree with behavior.
Treat everybody fairly
Do the rules apply for the CEO and down to
the new hire? The last thing you need as a
leader is a chink in that armor—that there are
different rules for management/leadership
than there are for the rest of the employees.
Everybody must play by the same rules, and
this is the purpose of a code of ethics. Here’s
my analogy: If you invite me to your house to
play a game, shouldn’t you explain the rules
before we play? And what happens if you
change the rules in the middle of the game?
What happens to your credibility and the
credibility of the game? That’s what a code of
ethics needs to do. These are the rules by which
we play here at this company; they will not
change and they apply to all. If you’d like to
join us, these are the rules. If not, then maybe
you need to find a job someplace else. That’s
the goal, but within the context of those rules,
that code of ethics (which includes mission

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January2016
statement and value statement and some kind
of putting these under one umbrella), the key
point is that everybody must play by the same
rules—everybody.
Be honest
If you have a short memory, always tell the
truth. If honesty is a moral principle, then don’t
chip away at it. Be honest. Yet, how many of
these moral obligations do we see in today’s
workplace? These obligations are innate
capabilities that leaders today more than ever
need to address, communicate, and model in
their organizations
To be morally aware, I have three
suggestions for you.
1. Commit to moral principles. Many
companies have value statements, but still
there are problems with many of those
companies, primarily because the principles
are nicely stated, but there’s a distinction
between what is stated and what the
behavior is of people in the company. There
has to be consistency and continuity. That’s
what commitment means—that what you
say is how you live. What you say is how
we do our business. What you say is how
our customers experience working with our
company. What you say, our vendors and
suppliers can count on also, unequivocally,
on how we do business with them as well.
2. The morally aware leader needs to
understand that there’s risk involved in
living out those principles. There are risks
in every decision that a leader makes, but if
you have a foundation of moral principles
and you know what is right, we need to be
sensitive and deal with the realization that
someone, somewhere on that leadership
chain isn’t going to like it. The question
is: Are you still willing to do it? Because
of those principles, are you still willing
to make the stand? Are you still willing
to speak out? And are you still willing to
stand up for those principles, those values,
in the workplace?
3. Have the resolve when needed, to pay
the price. I call this the “PTP” factor.
What is your price-to-pay for what you
want to do? Particularly as a leader, if you
can’t pay, you better walk away, because
there’s an absolute in life that’s just like
gravity—what goes around always comes
around, positive or negative. It all comes
around. Have the resolve. What’s your line
in the sand? Here’s where I stand. I will not
cross it.
Conclusion
Therefore, if we truly believe that good ethics
is good business, consider a large part of the
problem is failed leadership and the lack of
moral awareness. So what’s next? We can
start with the investment in the values-based
training for leaders of the organization and
work to instill a sense of moral awareness
throughout the organization, thus increasing
the odds that the gap between what is
professed as values and what is modeled in
behavior will become increasingly smaller.
Failed leadership and the lack of moral
awareness are both conscious choices. People
choose this. This is a rational choice. Can one
really say that one was not aware that there’s a
moral dimension to choosing? I doubt it. Failed
leadership—that’s certainly a conscious choice.
People choose to be dishonest. People choose
to cheat, etc. These are choices and as with
all choices, there are consequences, good or
evil. It is the leader’s responsibility to see what
others do not see, to discern what others may
not, and to act with fortitude, conviction, and
moral purpose. This then becomes exemplary
moral leadership. ✵
1. Available at http://bit.ly/skoutgroup
Frank Bucaro (frank@frankbucaro.com, 630-483-2276) is President at
Frank C. Bucaro and Associates, Inc. in Bartlett, IL.