We all have said it numerous times, “Managers should have an open door policy. The more comfortable employees are sharing with their managers the better chance we have of knowing what is going on and keeping up with the ethical needs and concerns of the organization.” Do we really mean it? If we do, is it a good idea?
Most companies do not have a way of capturing issues reported to managers as opposed to issues reported through a hotline. If the majority of issues are reported to a manager and never known to an ethics professional, then the statistics we all so carefully keep and use to evaluate trends may not be accurate at all. The adjustments we make to our programs to compensate for what we think are the pressing issues may not really be necessary or the best use of our resources. Employees will begin to feel that the ethics and compliance program misses the mark and only adds extra unneeded steps to getting their jobs done.
If this is not scary enough, most managers report that they just deal with issues which are brought to their attention. How can you know if the manager is giving the best advice or even providing correct solutions? All managers are not created equal—everyone has different strengths and weaknesses–and if an employee with a real problem goes to a manager who does not know how to address the issue but does not want to show his or her weakness by asking about it, what type of advice will that employee get? Will the correct solution be achieved? What about the employee who perceives their manager is unapproachable, or the manager who when he or she does not know what to do about something they are told chooses to do nothing? The issues these managers’ direct reports have won’t be resolved and may never even be heard.
These realities warrant questions like: “Is an open door policy a good idea?” “What would happen without an open door policy?” However, if we said all ideas had to come to the ethics and compliance department, things would probably be a whole lot worse. Just think how scared some people are of approaching compliance about issues they see or of reporting something on the hotline. Employees engage their manager all the time so having this avenue is critical.
So before thinking about closing the open door to managers’ offices, think about walking through it yourself. By truthfully examining the shortfalls of using managers as program messengers, it is easy to identify what needs to happen to make managers’ engagement in the compliance program an asset instead of a risk. If done right managers will be advocates and program champions. Some ideas include providing a managers tool kit and conversation starters to them, sharing with managers short videos of how to address tough situations and highlighting managers who have done something supportive of the compliance program and using the health and safety system managers have on their desk top to also report ethical issues which are brought to their attention. The key is to work to make the open door inviting and to assure when someone enters the manager knows what to do and how to capture the fact that something was raised. I can show you how to do this and help you accomplish these goals.
What do you think? Is an open door to your managers’ offices a good idea? Do we have a choice? What do you do to assure that managers are approachable, do the right thing and that compliance knows about it?