Rebuilding Trust After a $50M Ethics Crisis

Turning a compliance mandate into a culture-defining moment

CHALLENGE:

Following an ethics lapse and the resulting SEC settlement, the client increased ethics training from one hour a year to 12 hours annually. The mandate was clear. But commitment alone wouldn't change culture. The challenge was to make sure employees really heard the message, believed leadership was serious about it, and would feel safe speaking up.

ACTION:

We designed a comprehensive, integrated communications strategy to extend the benefits of training, foster a culture of ethical decision-making, and empower people to speak up. Here's what we did:

  • Leadership Communications: Developed messaging that positioned ethics as a core business value, not just a compliance requirement, with consistency across leadership voices and channels.

  • Multi-Channel Strategy: Bolstered training with a regular cadence of real-world audio, video, and online content including a "ripped from the headlines" story series called "From our Files," a monthly quiz on the Code of Conduct with a cash prize, an executive-level newsletter to keep leadership aligned, custom content for Vice Chairs to reinforce the tone at the top, and more.

  • "I Spoke Up" Podcast: Created a series featuring C-Suite and senior partners discussing real ethical dilemmas they had navigated in their careers. They told their stories in their own words, talked about times they'd had to make tough calls and, in some cases, wished they'd done things differently. The podcast became the client's highest-rated internal audio program because it allowed people to see ethics and integrity as something leaders actively thought about and not just something they enforced.

  • Data-Driven Optimization: Used analytics to track progress and refine the communications strategy on an ongoing basis.

RESULTS

  • Behavioral Change: Measurable improvements in training outcomes, employee engagement, and survey results.

  • Cultural Transformation: Fostered a "Speak-Up" culture evidenced by several metrics including a reduction in anonymous Ethics & Compliance Hotline reports. While the overall number of reports remained consistent, more of the people reporting felt comfortable identifying themselves, which indicated they felt safe and trusted the process.

  • Stakeholder Impact: Demonstrated quantifiable results through comprehensive data analysis and reporting. By measuring what mattered, we showed the movement from a culture of compliance to one in which employees internalized integrity as a value.

If you're trying to shift culture or make sure your people understand the direction leadership is taking, that's the work I do.

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