Building an Organizational Culture of Integrity: Key Strategies

Introduction

During an era in American history when charges of unethical business practices extend even into the highest levels of government, identifying opportunities to develop an organizational culture of integrity has assumed new importance and relevance. The purpose of this paper is to review the relevant literature concerning the importance of developing a culture of integrity and how this can be accomplished in organizations of different sizes and types, including law enforcement agencies. To this end, the construct of integrity is first operationalized, followed by a discussion of what strategies have proven effective in developing an organizational culture of integrity. Finally, a summary of the research and its implications for business practitioners in general and law enforcement authorities in particular are presented in the conclusion.

Defining Integrity

It is reasonable to suggest that most business practitioners understand what integrity means, even if they sometimes fail to live up to these standards in their personal and professional lives. Some straightforward definitions include Auletto and Miller's (2017) description of integrity as simply "acting with honesty in all situations" (p. 17) and Regina's (2017) characterization of it as the "daily demonstration of moral values and professionalism" (p. 41). Other common definitions include:

• Firm adherence to a code of especially moral or artistic values (Merriam-Webster);
• Adherence to moral and ethical principles; soundness of moral character; honesty (Dictionary.com); and
• The quality of being honest and having strong moral principles (Oxford Dictionary).

These definitions, however, lack the precision needed to develop an organizational culture of integrity. As operationally defined by Black's Law Dictionary (1990), integrity can be more accurately conceived as "soundness of moral principle and character, as shown by one person dealing with others in the making and performance of contracts, and fidelity and honesty in the discharge of trust" (p. 809).

In an organizational context, integrity can also be conceptualized as a "stool with three legs" (Lander & Nahon, 2015). According to this model, the three components are: (a) honesty — being open and truthful about one's feelings and acknowledging past or present wrongdoings; (b) responsibility — taking full ownership of one's share in all situations, especially conflict situations; and (c) emotional closure — the intent of any actions to close the psychological space and increase one's sense of community with self and others (Lander & Nahon, 2015, p. 74).

It is important to note that while integrity may exist along a continuum, the concept is essentially an "all or nothing" proposition. All three components must be present for integrity to truly exist in any organizational context at a given point in time (Lander & Nahon, 2015). This means that even when practitioners consistently demonstrate honesty in their business dealings and accept responsibility for their actions, integrity does not fully exist if they continue to hold grudges against others for perceived or actual wrongdoings. In other words, integrity can be an elusive organizational goal — but there are proven steps that corporate leaders can take to inculcate and sustain it throughout their organizations.

Developing an Organizational Culture of Integrity

There is a growing recognition among business practitioners across all sectors that unethical practices can have profoundly serious consequences for themselves and their organizations. The series of high-profile corporate scandals that have surfaced in recent decades underscores the seriousness of the problem. As Auletto and Miller (2017) emphasize, "The countless number of scandals over the past couple of decades has contributed to an increased focus on ethics. Companies are searching for a way to avoid scandals and develop an ethical culture at all levels of their organizations" (p. 16). As a result, the search for effective strategies to develop a culture of integrity has intensified, producing a growing body of scholarship that includes both spurious and legitimate guidance.

On the one hand, it is relatively easy for business leaders to proclaim that all employees will comply with organizational codes of conduct. On the other hand, actually achieving this outcome is another matter entirely. When corporate leaders advocate for integrity in the workplace but fail to live up to their own standards, the hypocrisy is readily apparent to subordinates — who will often respond in kind. A corporation that promotes integrity through a comprehensive code of conduct while routinely ignoring it at the leadership level simply sets itself up for unethical practices from the bottom up.

Just as integrity can be conceptualized as a three-legged stool, so too is the process of building a culture of integrity — one in which consistency and conformity with ethical standards among all stakeholders receive the highest priority. As Auletto and Miller (2017) note, "It has become increasingly evident that ethical principles need to be introduced to employees long before they are involved in an ethical dilemma. Ethics need to be a priority, not just at a corporate level, but also to individuals" (p. 17). Even if corporate leaders model ethical behavior, that alone will probably not be sufficient to develop a full organizational culture of integrity.

One of the most common strategies for developing and sustaining such a culture is the use of codes of conduct (Tinsley, 2002). As Allman (2009) reports, "Effective detection and prevention of law or ethics violations require publicizing the values and imperatives deemed important by an entity's leadership. Most corporations have promulgated codes of conduct and provide training in the entity's significant values" (p. 55). Additional steps that have proven effective in developing and sustaining a culture of integrity in both public and private sector organizations are outlined below.

Step One: Designate a Compliance Owner

Any compliance program must have a designated owner — often called the "compliance officer" or, preferably, the "compliance and integrity officer" — to signal that the program is about doing the right thing, not merely satisfying legal requirements. This person should be a well-qualified member of senior management with direct access to the organization's governing body and with reporting responsibility to the top tier of executive management.

Step Two: Implement Written Standards and Procedures

Every organization needs a code of conduct that applies to all employees and to those who perform work on the organization's behalf. The code is an important vehicle for communicating executive management's commitment to organizational culture, ethics, integrity, and compliance. The document should state the organization's mission, goals, values, and compliance standards, plus the requirement for appropriate staff to adhere to their professional codes of conduct. The risks addressed in the standards should track the organization's risk profile, with greater attention given to high-risk topics such as harassment, health and safety, and conflicts of interest.

Step Three: Conduct Appropriate Training and Awareness

As part of the compliance program, organizations should require periodic training for all employees and contracted staff. This is essential to communicate and reinforce values and standards, meet legal obligations, and mitigate legal, reputational, and operational risks. Training can also help change behavior and reduce instances of wrongdoing through prevention. Building an effective training and communication plan begins with identifying risk areas, determining which audiences need education in each area, and establishing the depth and frequency of training based on job roles and risk exposure.

Step Four: Develop Open Lines of Communication

Offering employees a safe way to report problems is critical for a strong organizational culture. Fear of retaliation is one of the most common reasons that staff refuse to speak up about misconduct. Organizations should encourage open-door reporting to management, maintain a direct line of communication to the compliance officer and compliance committee, and provide anonymous reporting channels where permitted. These typically include a toll-free helpline and a web-based reporting system. Publishing anonymized summaries of issues that have been addressed can further combat skepticism and improve organizational culture by demonstrating that reports are taken seriously and acted upon.

Step Five: Centrally Manage All Reports and Allegations

All reported concerns should be added to a centralized database that also captures helpline reports, web-based submissions, and cases reported directly to compliance staff and managers. A good case management system enables consistent data collection across departments, geographies, and personnel. This allows compliance professionals to conduct aggregate analyses so that data trends can inform improvements in policies, training, and processes. Connecting data from across the organization can also be a valuable tool for detecting and correcting broader systemic problems.

Step Six: Respond Consistently and Appropriately to Alleged Offenses

Reports of misconduct cannot be ignored, dismissed without inquiry, or left unresolved for extended periods. Case managers must respond to all reports promptly to confirm receipt and indicate that the matter is under review. Cases are typically triaged by type of issue, and a determination is made as to whether they can be handled directly or require a formal investigation. All investigations should follow a written protocol to ensure consistency and to involve the appropriate personnel. Depending on the allegation, organizations should consider engaging outside resources — such as lawyers or auditors — to assist with certain investigations.

Step Seven: Audit, Monitor, and Adapt as Needed

Compliance programs should include auditing and monitoring for violations of laws, policies, and standards of conduct, as well as audits of compliance program processes to ensure effectiveness and identify areas for improvement. Audit plans should be re-evaluated annually, with consideration given to prior findings and new risk assessments. Results should be shared with the compliance officer for analysis and implementation of needed improvements. Achieving a strong organizational culture of ethics requires more than adding rules and controls — it demands an integrated effort that aligns financial and compliance requirements with the organization's mission and values. When positioned this way, employees are far more likely to understand and accept the necessity of compliance (Adapted from Understanding the Basics, 2018).

The foregoing steps are relevant for virtually any public or private sector entity, but law enforcement organizations have unique considerations that must also be taken into account when formulating initiatives designed to develop and sustain a culture of integrity (Jacocks & Bowman, 2006). While the process begins at the top — just as in the private sector — law enforcement organizations can also benefit from specialized training programs designed to provide police officers with the skills needed to navigate complex ethical dilemmas and avoid even the appearance of unethical conduct (Jacocks & Bowman, 2006).

Conclusion

The research demonstrated that the adage "individuals are not honest just because they have never had the chance to steal" applies to virtually every type of public and private sector organization, as the long list of high-profile corporate misconduct cases that have dominated the headlines in recent years makes clear. Consistently acting in an ethical fashion may be a universal expectation for all employees, but people frequently fail to live up to these expectations by engaging in fraudulent activities that harm their organizations or others while unjustly enriching themselves. When such unethical practices occur in law enforcement organizations, the stakes are far higher and the implications more severe, since communities place an enormous amount of trust and faith in the police to not only uphold the law but to comply with it as well.

References

Allman, T. Y. (2009, March–April). Fostering a compliance culture. Information Management, 39(2), 54–59.

Auletto, K. T., & Miller, A. J. (2017, April). Developing more ethical leaders. Techniques, 92(4), 16–19.

Black's law dictionary. (1990). St. Paul, MN: West Publishing Company.

Jacocks, A. M., & Bowman, M. D. (2006). Developing and sustaining a culture of integrity. The Police Chief, 73(4), 16–22.

Lander, N. R., & Nahon, D. (2015, Fall). The integrity model: An existential approach in working with men, culture, and identity. Culture, Society and Masculinities, 7(2), 73–78.

Regina, N. (2017, Winter). A lesson plan for developing internal culture while launching an external brand. Momentum, 48(1), 40–44.

Tinsley, P. N. (2002, Fall). Codes of ethics and the professions. CACP, 9–11.

Trautman, N. (2009, January). Special report: Ethics — truth about police code of silence revealed. Law & Order, 49(1), 68–71.

Understanding the basics. (2018). Compliance Next. Retrieved from https://www.navexglobal.com/compliancenext/understanding-the-basics/