Can hand soap and flowers really tell us about a business, its culture and its values? Short answer – yes. But before I get to that, a little background on culture from an ethics and compliance perspective.
Business folks at times will ask me, why in the world do we even have to have an ethics and compliance program. (Lawyers ask too.) The reason – the government says so. The government sends out this order through different channels. One is the Federal Sentencing Guidelines which tell organizations that they have to have an ethics and compliance program and the Guidelines even spell out what that program should include. Among other requirements is that “an organization shall promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.” (Federal Sentencing Guidelines for Organizations, §8B2.1).
The next question I get is “dearest lawyer – I am never going to be sentenced for a crime, so why do sentencing guidelines even apply to me or my business?” Well, first, as a great risk management executive would often SCREAM at business folks when they would raise such a question to him on a risky proposition: “FAMOUS LAST WORDS.” In other words, never say never especially in business and law. That is one reason. Lets hope you nor your organization ever do face sentencing but in the event it happens – you better have a program. (That is a tale for another blog post.)
But there is another reason. Depending on the type of business you are in, you may be mandated to have an ethics and compliance program. If you are a Federal Government contractor, doing a certain amount of business with the Federal Government, you are must have an ethics and compliance program. And you represent when you submit your bids that you have such a program. This regulation also, among other things, states that contractors must “promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.” (FAR Ethics & Compliance Requirements).
There are many other legal and regulatory schemes that require an ethics and compliance program. All the schemes require that businesses promote a culture of ethical conduct and commitment to complying with the law. When I introduce this idea to business folks many ask how will they ever know if they have a culture that promotes ethical conduct and a commitment to following the law.
If you look around your business, especially at the little things that may seem of no consequence unless you think about it, you can find your culture. Which brings me into your restrooms – where I submit you can get an idea on culture and values.
There are businesses whose offices are gorgeous and opulent. They have beautiful fresh, potted flowers that are regularly replaced in the restrooms. They have original artwork. They have lovely handcrafted soaps, handcrafted lotions, mouthwash, cloth towels, hair products, and deodorants in the restroom.
There are other businesses whose offices are utilitarian and practical. They have no flowers or original artwork anywhere. In the restrooms, they have paper towels and softsoap – that’s it.
This information says a lot about each business. The business with the fresh flowers values exclusivity, image and they create an exclusive culture with the flowers, the artwork and the handcrafted soaps. Their CFO is a-okay with the spend because she knows that their offices need to be opulent and exclusive to appeal to the client they want to attract and to the employees they want to attract. Their clients are probably fine with paying top dollar for their products or services.
The business that has paper towels and soft soap is about practicality and frugality. Their CFO would have a cow if she saw expenses for fresh flowers, artwork and handcrafted soaps. And, their clients and employees don’t expect it either. Chances are their clients would probably be taken aback if they saw fresh flowers, artwork and handcrafted soap. They would perhaps wonder if they were overpaying for the product or service.
This is how hand soap can be a clue about cultures and values.
So, if at some point you look around your business and wonder if your organization values integrity and compliance with laws – take a look around at the small things. Do people feel like they can puff up your business’ capabilities when submitting a proposal? Are people honest on their expense reports? Do people ask the lawyers about what the legally correct course of action is or do they just press on? Do leaders talk about doing the right thing and then do it? Do people know where the policies are, do they know the policies, and do they follow the policies or, are policies just sitting on a shelf? Do managers treat their teams with respect and encourage dissent or at least encourage asking hard questions?
Just as the type of soap in your restrooms can give an idea on your business’ values from a spend perspective – the answers to the above questions can give an idea on how your organization is doing from an integrity perspective. So take a look around.
“Men acquire a particular quality by constantly acting in a particular way.” Aristotle