Insights and Outcomes from Benchmarking Ethical Culture
“We thought we really had to be more comprehensive in gauging employees perceptions of our program. We picked the Ethisphere Assessment because it looked at all aspects of our program, including areas we have been focusing on, like awareness of resources, our employees’ level of comfort reporting concerns, and their perception of organizational justice. We also liked the fact that it took less than 10 minutes for most employees to complete the entire survey, and that we could benchmark it against peer companies.” – Kathleen Franklin, Global Ethics and Compliance Strategy Leader, Sony Corporation
Headquartered in Tokyo, Japan, Sony Corporation is a multinational conglomerate whose diversified businesses include game & network services, home entertainment, music, movies, semiconductors, and other businesses. It has about 117,300 employees worldwide, 13% of whom work in the U.S., and over $78.7 billion in revenue.
In 2018, Sony implemented Ethisphere’s Ethical Culture Survey to selected businesses in its Global Entertainment and Americas region. The goals were to better understand employee perceptions of its ethical culture and its compliance program, and to ensure that it was meeting U.S. Department of Justice expectations that corporations conduct a thorough assessment of ethical culture. Before this survey, the compliance function had included questions regarding culture in the annual, general engagement survey.
Featuring: Kathleen Franklin, Global Ethics and Compliance Strategy Leader, Sony Corporation
Fostering a Culture of Compliance
“Our leaders model desired behaviors by setting the right tone at the top, reinforcing through daily interactions that ethics are important and taken seriously, talking about the importance of ethics and doing the right thing, and embedding ethical values into everyday actions so that employees gain a sense of ‘how we do things around here,’ which is then integrated into daily activities.” – Joan Kissel, Executive Vice President & Chief Ethics Officer, Old National Bank
Old National Bank, founded in 1834, is a service- and community-focused financial institution serving Indiana, Kentucky, Michigan, Minnesota, and Wisconsin. The company has been a World’s Most Ethical Companies honoree every year since 2012; and has also been recognized by the National Organization on Disability (NOD) as a 2019 Leading Disability Employer; has received a 2019 Military Friendly Top 10 Employer designation; and was named to the 2019 Bloomberg Gender-Equality Index (GEI).
At Old National Bank, the ethics and compliance programs are jointly let with nearly 40 full-time associates across the two areas. The ethics function is managed by the Chief Audit Executive & Ethics Officer who reports functionally to the Audit Committee of the Board and administratively to the CEO. Risk assessments related to program elements, such as tone from the top, culture, personnel, and fraud are managed by the audit department. The compliance function is managed by the Chief Risk Officer (CRO) who reports functionally to the Enterprise Risk Committee of the Board and administratively to the CEO. The CRO is responsible for enterprise risk management and bank-specific regulatory compliance.
Featuring: Joan Kissel, Executive Vice President & Chief Ethics Officer, Old National Bank
JLL and Ethisphere’s Program Assessments
“A lot of the things we’ve developed have come from being part of Ethisphere’s community and getting these assessments, because that’s where we hear about the importance of training and get ideas about what other companies are doing. Ethisphere is our primary connection to best practices in the business community and the concentrated source of wisdom about how to keep raising our game.” – Mark Ohringer, Executive Vice President, Global General Counsel and Corporate Secretary, JLL
Even if you don’t know the name, it’s very possible you’ve been in one of JLL’s buildings, since they manage over four billion square feet of commercial and residential space in over 80 countries around the world. In each building, the owners trust JLL’s team to act ethically. For the last ten years, Ohringer has relied on Ethisphere’s Program Assessments as a key barometer for how JLL’s ethics and compliance program is helping further that mission.
Featuring: Mark Ohringer, Executive Vice President, Global General Counsel and Corporate Secretary, JLL
Building, Assessing and Maturing a Global Anti-Corruption Program
“Tone at the top has been a key factor to the success of our program. Our leaders are convinced that acting with integrity every day is the only way to do business.” – Mavin Dominguez Arroyo, Corporate Compliance Officer, Grupo Bimbo
Five years ago, Grupo Bimbo had a very small compliance team that was centralized in the headquarters in Mexico. The company recognized the need to expand its program across its global brands to align with its corporate commitment to integrity and to meet diverse compliance requirements. Since that time, Grupo Bimbo has worked steadily to implement an anti-corruption program that is now highly mature and embedded throughout its global organization…
“We have experienced growth every year. Last year we were in 22 countries, and now we are in 32. As we grow and acquire companies, we need to assure that our compliance program not only works in Mexico, but throughout the world.”
Featuring: Mavin Dominguez Arroyo, Corporate Compliance Officer, Grupo Bimbo
Partnering with Senior Leadership on Ethics and Compliance
In this spotlight learn how senior leadership work to embed ethics and compliance across the diverse teams at CareFirst.
CareFirst BlueCross BlueShield, an independent licensee of the Blue Cross and Blue Shield Association, is a not-for-profit health care company that, through its affiliates and subsidiaries, offers a comprehensive portfolio of health insurance products and administrative services to 3.2 million individuals and groups in the mid-Atlantic.
CareFirst is a member of the Business Ethics Leadership Alliance (BELA) and a seven-time World’s Most Ethical Companies® honoree.
Featuring: Todd Cioni, Vice President and Chief Compliance, Ethics, and Privacy Officer
CareFirst