Behavioral Ethics & Compliance Risk Assessment

The basic notion of assessing ethics and compliance (E&C) risk is no longer novel at many companies, as it once was.   Indeed, some businesses may need to find ways of refreshing E&C programs.  Conducting a behavioral E&C risk assessment can be one way of doing this.

Mechanics of assessment

The measures for undertaking a behavioral assessment are simple enough. They generally entail utilizing behavioral E&C questions/ideas in employee surveys and interviews.

Such efforts can be conducted either on a stand-alone  basis or as part of broader E&C program.  Whichever you select you should be aware that unduly lengthy surveys or interviews might be seen as overkill.

Substance of assessment

While the mechanics of behavioral E&C assessment are fairly straightforward the same cannot always be said for the substance.   This will often require the exercise of “outside of the box” thinking. 

That is, practitioners may need to draw broadly from behavioral E&C literature, law and publications, among other things) to craft an assessment program that works for their respective clients.  In effect, this is a needs assessment for a risk assessment.

What should be in that body of knowledge? There is, as of yet, nothing  official on this score. But the following posts to the Conflict of Interest Blog might be helpful in this regard. (Note: you may need to access some of these by Control Click.)

 Being rushed as a source of risk

Slippery slopes 

Senior managers 

Long-term relationships

How does your compliance and ethics program deal with “conformity bias”? 

Money and morals: Can behavioral ethics help “Mister Green” behave himself?  

Risk assessment and “morality science”  

Advanced tone the top       

What to do with the behavioral assessment information  

There are several possible uses of behavioral E&C information. One can:

  • Add a discussion of it in all-employee communications, such as emails from senior managers or office newsletters
  • Use it to enhance training by creating scenarios that illustrate key behavioral points.
  • Work the information into compliance audit protocols.

Finally adding a behavioral E&C dimension should be interesting and therefore  help maintain focus on  a company’s  program.

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