Ethics Whisperer

Wednesday, January 14, 2009

The Dog That Didn't Bark

More on gifts and such. If you want to train a dog to do anything, you first train it to sit and stay. Trust me on this as I have three little beauties. Why? If the dog doesn't respect your authority in this matter, you are unlikely to train him/her to do really difficult things like not eating the other dog's food. Now the job of a compliance officer is to train the members of his/her organization not to cross certain lines. You are in the invisible fence business. Now if you can not convince the organization to accept a specific dollar limit on the value of gifts, you are unlikely to get key managers to avoid hair brained schemes that promise to make them rich. You have to win one battle to show that you have the authority to set some boundaries. When I see codes and policies that talk about gifts being limited to what is usual and customary or reasonable given the circumstances, I take that as a sign that the organization may be beyond hope. If I get hired to help, we may well start with a gift policy.

Once upon a time, a senior executive of a publicly traded healthcare company was sent a St. Andrews putter - gold plated with his name on it - by a vendor, the company's law firm no less. He wanted to keep it so badly he teared up. He then told his admin to send it back to the vendor who had given it to him. The admin immediately told the other admins what happened - "They have gone completely crazy over this ethics stuff; Mr. X actually sent back a St. Andrews putter." And the organization was changed.

I, however, can accept the putter. So be kind!

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