GUEST POST FROM RICHARD BISTRONG
Can a sales or business development person succeed around the world, while staying on the path of an anti-bribery and ethical program? [spacer height=”20px”]
In The Ultimate Excuse, Andrew Leigh offers the bell curve of employee ethics. Most employees (93%) are committed or neutral. This got me thinking. What might shift this this majority to become “ethically engaged employees?”
The trouble with rewards is they can distort behaviour. A company gearing financial rewards to a person’s individual sales performance can dilute or even discard the compliance message.
The International Sales Perspective
Sales Executives and their supervisors are usually far removed from the places where corruption is confronted . In contrast, it is the front line sales force who face the worst risks of corruption. They tend to travel alone when meeting agents and officials. Most often, no one else is present during these meetings, and there is very little senior oversight. These employees are left to make hard ethical choices.
Thus, each person on the front line of sales needs to be a true stakeholder–someone who lives by the basic message of no tolerance, “doing what’s right, even though no one is looking.”
For example, when faced with a corrupt event, the Chief Counsel for Siemens, described the reaction of one of his Country Managers who said, “no” but more importantly, stated[spacer height=”20px”]
it’s not because compliance says I can’t do it, it’s because I don’t do it.”
Dow Jones Global Compliance Symposium, 2013
Thus, Compliance can only be as strong as the fortitude of the one who faces it most, and C-Suite executives should consider that when developing compliance and training programs for their overseas employees and teams.
No one gets hurt
The impact of bribery on good governance, poverty, and standards of living provide a rich source for writing and research. Few sales people, though, consider:[spacer height=”20px”]
What does a bribe mean in a societal sense to those living where bribes occur? [spacer height=”20px”]
Instead, the goals of making sales plan and bonus tend to triumph over this broader view of bribery and governance. Thus, employees rationalize the risks and ignore the anti-bribery ethic.
Again, there are a number of factors which contribute to the “perfect storm” of rationalizing corruption.
First, is the lack of witnesses and oversight in overseas environments. Second is the illusion that “no-one gets hurt”—there are no victims. However, the reality is different, which challenges firms to take wider view of how their overseas teams think about bribery, ethics and compliance.
Compliance As Bonus-Prevention
The link between reward and compliance becomes vital when a territory has a reputation for low integrity. If a large portion of compensation stems from individual sales performance, the compliance message may become distorted.
In such an environment, the sales person may see compliance and pay as a zero sum game—they both can not exist together. They start to consider:
“What are my deliverables; what does my sales manager want, compliance or sales?”
Recently I shared these concerns about the negative impact of individual incentive compensation with a compliance professional in Europe. He argued the C-Suite message is too often one of compliance and anti-corruption, while still “paying to win”.
Managers who say one thing, yet reward something else, can cause serious damage to both individuals and the company. They leave the sales person to figure out the priorities.
A shift towards a more ethical culture can only be driven by senior leadership. It cannot be left to the sales person to figure out corporate, group and individual goals. By bringing individual incentives in line with desired company behaviours the aim must be to make ethics the default “go-to” when corruption is confronted.[spacer height=”20px”]
People need to understand that the company is not just concerned with profits or sales, but how people get there.”
The Ultimate Excuse
When financial incentives really do reward people for “getting there,” then perhaps the bell curve shift can start to happen.
Richard Bistrong blogs about FCPA Real-World Compliance Issues at www.richardbistrong.blogspot.com and on twitter at @richardbistrong
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