Implementation

In many organisations ethical business practices have been embedded through the introduction of comprehensive programmes and/or documentation. Any company that plans to implement, review or refine their ethical business practices needs to do so in a tailored fashion as each has different needs, resources, and issues. However, the following guidance will assist in determining what must be considered when putting ethical practices together.

Of the opinions sought for this research the most commonly cited organisational ethics practice was the use of Codes of Ethics or Codes of Conduct. Brandl and Maguire (2002) note that there is a difference between a Code of Ethics and a Code of Conduct. A Code of Ethics "is generally a more blanket statement of values and beliefs that defines the organisation or group. (it) Usually has two key elements: aspirational ideals outlined in the beginning, followed by rules or principles that members of the organisation are to follow.  There are often different sections regarding specific relationships with employees, customers, shareholders, suppliers, and competitors, as well as society in general". Brandl and Maguire identify a Code of Conduct as being a document that "addresses the values of the group or company and how the values reflect those of society as a whole".  The Ethics Resource Center in America, views a Code of Conduct as a document that outlines a fundamental set of principles and that it helps explain why behaviour is directed in a certain way, and why certain actions are required or prohibited.

Brandl and Maguire summarise the differences between the two, stating "Codes of Ethics are general guides to operational values and decisions, while Codes of Conduct are more specific or formal statements of the values and practices of a business. Codes of Conduct often contain examples of appropriate behaviour and specific prohibitions and may begin with a mission statement".

Deborah Hopen (2002) who wrote on corporate behaviour for The Journal for Quality and Participation states that "To be successful, Codes of Ethics need to be specific, but not overwhelmingly detailed. They need to be understandable and aimed at helping individuals at all points of the organisation make good decisions. Understanding isn't build through longer documents but through discussion, education and training, leaders' demonstration and employees' guided practice". Hopen notes that there are 6 primary areas that are addressed in the Codes of Ethics in most organisations:

• Conflict of interest

• Records, funds and assets

• Information

• Outside relationships

• Employment practices

• Other practices e.g. employee health and safety, political activities, the environment.

The American-based Institute of Business Ethics recommends the following eight general steps when in the initial Code of Ethics/Conduct planning phase:

Max Messmer (2003), Chairman and CEO of American based Robert Half International Inc., notes the need for an ethics programme and identifies six components to an effective programme:

• Leaders set the example - employees often model their own behaviour after executives and managers and everyone, at every level, must adhere to the company's ethical guidelines;

• Ethics is a core value - ethics should be a core value of the corporate culture;

• Everyone participates in rule making - as policies need to reflect the challenges that employees routinely face, input from people from all levels in discussions about the development of ethical guidelines is valuable;

• Ethics is discussed openly - ethics is included in orientation and training programmes, and is raised during meetings and on-on-one conversations with staff;

• Rules are applied consistently - the same ethical standards should apply to everyone and consequences should be consistent across all staff; and

• Employees feel safe to share concerns - staff should feel they can raise ethical issues without fear of negative career consequences or other repercussions.

Brandl and Maguire also highlight the need to:

Rather than highlighting a Code of Ethics or Conduct, Niedermeier and Rhodes focus on the need to make good decisions and the use of an appropriate decision-making model to do so. They also highlight the need for role modelling from senior management, deliberate instruction and ongoing training using scenarios and guided discussions. They do note that decision-making is difficult due to factors that can influence any high-level decision. They suggest that time, earnings expectations, public opinion, industry/market shifts, government regulations, personal performance goals and peer pressure (amongst others) as being some of the criteria that influence decision-making. Clarifying the criteria by which employees make decisions is considered their first step in improving decision-making, and creating and using a 'values toolkit' as the easiest way to most clearly communicate what is important within the company. For Niedermeier and Rhodes a decision-making model that encompasses the three core values of 'accountability', 'integrity' and 'transparency' will be the most effective in promoting more responsible decisions.

Jeffrey Lovitky (a healthcare attorney) and Jack Ahern (from Rush Presbyterian St Lukes Medical Centre) (1999) focus on the need for a compliance programme. They suggest that a Compliance Officer should be employed at a senior management level, with a Compliance Office team for larger organisations. To support the integration of the programme throughout the organisation and to support the Compliance Officer or team, a Steering Committee and committees that serve specific functional areas within the organisation are also needed. The Compliance Officer should also be regularly reporting to senior management and the Board of Directors on ethical issues.

Lovitsky and Ahern see a comprehensive written Ethics Code as a starting point for any well-run compliance programme, with additional policies for various departments supporting the Code. A well publicised hotline to enable employees to report suspected fraud, waste or abuse is also suggested. The need for internal or external periodic auditing of the Compliance programme is also highlighted with the audit evaluating all areas of the Compliance Programme including:

Hopen also discusses 'whistleblower' situations and states "Processes must exist for reporting questionable activities, protecting the whistleblower, investigating each and every reported incident, taking action, and appropriately communicating the situation and action taken so that the violation won't be repeated and organisational learning increases".

Training and education using organisation specific scenarios is highlighted by all experts as a critical component of an Ethics Programme, or as a way of ensuring staff know about and follow a Code of Ethics or Conduct. However, Steve Priest, founder of the Ethical Leadership Group, believes "The people who present the least risk - legal, ethical and reputational - to the company, the employees, receive the most training. The people who present the most risk to the company - senior management and the board - receive the least". All experts also agree that training should be continual, interactive, and practical. Chris Verschoor from DePaul University in America highlights several important outcomes when companies provide training programmes in ethics:

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