
Standards for waivers of conflicts of interest
While some organizations bar conflicts of interest in all cases, many opt for allowing COIs to exist where appropriate. But how should appropriate be defined for these purposes?
“We built this company on a culture of integrity. Nothing is more important than how we treat each other. You should count on your leaders to create a safe and respectful workplace. When our principles and policies are violated, we will always move quickly to take appropriate action, as we have done here.”
The above is from the memo that Comcast top leadership apparently sent to employees announcing the departure of NBCUniversal CEO, Jeff Shell, following a third party investigation that found he had an “inappropriate relationship” with an employee.
Comcast’s statement hits several important points:
1. A culture of integrity matters. Culture is not what organizations simply say they want it to be, but reflective of what is allowed within the organization and what employees perceive and experience. A culture of integrity sometimes requires big decisions like telling a CEO to leave for inappropriate behavior;
2. Leaders (and managers and supervisors) are key to building a culture of integrity. Leaders can do great things to support an organization’s commitment to integrity, but can also easily undermine it when they don’t act as they should;
3. If written/stated standards are to be worth the paper they are written on, they need to be applied in practice and that includes holding top leadership to those standards the same as everyone else;
4. If you want to make sure employees know your standards and values matter, then make it clear when a top executive is being let go for wrongdoing or other inappropriate behavior. Comcast’s message is clear – they expected more from the NBCUniversal CEO. No sugar coating the message or quietly letting the CEO simply “retire” without mentioning the real reason.
The last few months have seen a few other top leaders at various companies lose their jobs for integrity issues. Replacing CEOs and other C-suite leaders is expensive and disruptive to organizations, but keeping CEOs and other C-suite leaders who are not leading with integrity will cause more harm and damage in the long run.
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While some organizations bar conflicts of interest in all cases, many opt for allowing COIs to exist where appropriate. But how should appropriate be defined for these purposes?
Attending SCCE conferences is always a source of insights and new information. In these conferences I have seen quite a bit of focus on data analytics, and deservedly so.
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