The problem of designing and implementing a system of inquiry into code-of-ethics compliance can be approached in two ways – process based and outcome based evaluations. A sound data collection plan that would use surveys, interviews and focus groups, and direct observations will be the key instrument in either of the approaches. The measure of Organizational culture is another important component in the evaluation process. And an analysis of the indicators of the overall program performance forms the essential last step that consummates the inquiry.
The basic purpose of a compliance program for following the code of ethics is to help the employees at all levels and functions within the organization to work together and achieve the broader and narrower goals and objectives in such a way as to be consistent with standards of ethical behavior. The ethics compliance program and the system of inquiry is an essential part of the learning process for the organization.
It is recognized as a good practice to always evaluate the ethics program, although as a matter of fact, few organizations actually do so. On top of that, such programs normally have not demonstrated that the expected program outcomes were achieved. Still, the program could be deemed a success, if it at least met the minimum requirements. In this context, it is no longer a question of whether to inquire into one’s ethics compliance program, but rather to design a system of inquisition that goes about implementing it across a span of time. The following pages will delve into the framework for the system of inquiry and the related issues during its design and implementation.
The Code of Ethics
Principle 1: Society
I will uphold the health, safety and we...
lfare of wider society, future generations and the environment.
Principle 2: Organization
I will serve my employers and clients honestly, competently and diligently.
Principle 3: Peers
I will respect and support the legitimate needs, interests and aspirations of all my colleagues and peers.
Principle 4: Staff
I will encourage and assist those I supervise both to fulfill their responsibilities and to develop their full potential.
Principle 5: Profession
I will strive to be a representative of my profession and to promote the vision of the organization.
Principle 6: Self
I will be honest in representing myself and will continually strive to enhance both my professional competence and my ethical understanding.
Two approaches to Inquiry
Process Evaluation is designed to analyze how successful program implementation was. It is also designed to monitor which of the activities within the program were performed and to what extent. An instance of process activities and their corresponding output measure is the standards and procedures written and published through annual training courses in ethics. Regarding the participants of such courses, the extent that specific skills and knowledge were recollected at various periods of time after the training is an important indicator. And finally, the measure of participants’ satisfaction during the training is another valuable piece of data.
From the point of view of the inquirer, these program activities and their outputs have negligible value in and of themselves, especially when it comes to forming remedial actions. Their value is much more indirect, but ultimately significant. When it comes
to specific requirements, their value would be directly proportional to the extent to which they contributed to achieving program outcomes. To the contrary, if these activities and outputs do not contribute to the attainment of desired program outcomes, they offer very little value, and could be perceived as wastage of resources.
An outcome-centered evaluation, on the other hand, is necessarily concerned with the degree to which the program activities achieve their expected results. Some of the parameters that are measured are changes in the lives, attitudes, and behavior of the organization’s employees, agents and other stakeholders to go with broader changes across the organization. While performing the inquiry, it should be kept in mind that factors other than program activities would likely have some influence on the behavior, significant or not. In this respect this method of inquiry is less accurate compared to Process Evaluation.
The following outcome questions can be used for generic evaluation by managers and other authorities of the organization:
- Has there been a reduction in misconduct?
- Has there been less exposure to risk for misconduct?
- Are employees able to consistently recognize business conduct issues on the job?
- On how many occasions did the employees and agents speak in terms of procedures, standards and expectations?
- How frequently are decisions made with reference to procedures, standards and expectations?
- Are employees and agents willing to seek advice when required?
- How willing are employees and agents in bringing notice to concerns?
- How satisfied are employees who bring such notice with the management’s response?
- How dedicated are employees to the organization?
- What is the satisfaction level of stakeholders with the organization?
- To what extent does the culture of the organization promote ethical conduct, and discourage misconduct?
Developing a Data Collection Plan
There are wide ranging methods of data collection for evaluators to consider in gathering data for tracking organizational culture, relevant context scan, and process and outcome assessment. These include interviews, surveys, focus groups, document review, and direct observation. No single method is suitable for all purposes and each method has its own strengths, weaknesses and demands on resources. The bottom line is to develop an efficient and inexpensive data collection plan that encourages the employees to give their honest opinions, so that the evaluators, other authorities and stakeholders get a clear picture of the status of various aspects of the organization.
It is here that surveys and document reviews come in handy. Not only are they an effective tool for data collection but are also relatively cheap. Further probing can be followed on from the initial leads gained, impressions formed, focus groups, interviews, etc. It is to be noted that some evaluations can only be done through direct observation, which is a touch expensive. Unless third parties are involved in this data collection effort, it is practically impossible to assure anonymity and confidentiality, which are essential factors in eliciting candid responses.
Commonly Used Data Collection Methods
These are standard written instruments that contain a list of questions about the issues to be evaluated. They include a combination of types of questions, e.g., single, direct questions, questions with yes/no answers, series of questions about the same topic
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