Page 18 - PCCA Journal 1st Quarter 2012

Basic HTML Version

PCCA Journal|1
st
Quarter 2012
18
a part of company culture in multigenerational firms, but
as a company grows, instilling those values into the culture
becomes more difficult. Many firms interviewed went about
drafting a formal ethics policy that incorporated long-stand-
ing values that employees already identified with. Peter Beau-
pre, president and COO of U.S. operations for PCL, explained
the importance of a clear policy. “In the dozens of decisions
that each person is making each day, there are many that
are made on the spur of the moment by people at all levels
of the organization,” he said. “When they are making those
decisions, we want the whole notion of ethics—what is right
and what is wrong—at the front of their minds.” Most firms
use a combination of a code of conduct, ethics and compli-
ance policy, and annual training to communicate the basics
of their ethics program to employees.
Get buy-in from everyone in the company.
Mike Futch, vice president and chief counsel at Granite
Construction Inc., emphasized the importance of driving cor-
porate policy out into the field. “You’re always going to get
resistance from people in operations because they feel it is a
soft mandate from management, but you have to convince
them that it is everything to do with the project,” he said.
Sentencing guidelines also require continued involve-
ment of the board of a company. “A well-documented board
resolution adopting the program and appointing the compli-
ance officer, periodic reporting by the compliance officer to
the board or the audit committee with respect to compliance
activities, and periodic board training on compliance demon-
strate personal investment and buy-in at the highest level of
the company,” Futch said. Self-report measures, on-site train-
ing, and field audits are good ways to promote awareness of
ethics on the jobsite. Many companies get employees to sign
paperwork to signal that they have read and comprehended
the ethics policy or code of conduct. Dominick Servedio,
chairman and CEO of STV, believes that “ethics are critical in
our business, and the code of conduct is the foundation. You
have to live what you preach. There has to be transparency
at every level, and you have to educate employees before you
ask them to sign on the dotted line.”
An ethical culture starts with hiring the right people.
Good corporate parenting is responsible for the strong ethical
culture at Sundt. Check references and explore a potential
hire’s values on a job application and during the interview.
“As you grow and hire and expand, if you bring people from
Company X, maybe they have the same training, but maybe
they don’t,” said Sundt Chairman and CEO Doug Pruitt.
“You’re the one setting an example.”
New hires also offer a company an opportunity to build
certain values into a generation. “If you already are an ethical
company and you’re training the young people who join you
in what is expected of them, then when they’re in manage-
ment roles 20 years from now, it’s completely engrained,”
said Jim Moynihan, chairman, president, and CEO of Balfour
Beatty Infrastructure and Balfour Beatty Rail. Take the next
step by implementing mentoring programs to foster a rich
understanding of corporate accountability.
Ethics can be taught.
Many of the games played by various entities on a project
can be circumvented by addressing them up front on the
contract or through a partnering agreement. Setting down
specific language around change order expectations can limit
the latitude a project partner can take. Likewise, addressing
ambiguous situations directly can help employees avoid mak-
ing the wrong decision in the future. Practicing ethical ratio-
nalization through scenarios equips employees with the tools
to avoid unethical behavior. “Sometimes there is no black
and white answer,” said Doug Woods. “So you have discus-
sions about those kinds of things and how you might want to
be treated and how you might want to handle the situation.”
Review, monitor and report ethics behavior.
Regulations give federal contractors responsibility for discov-
ering and reporting unethical practices within their firms.
However, for firms choosing to implement ethics programs
at their own behest, accountability is still an important
component. Build multiple feedback mechanisms into your
program; an open-door policy, hotline, self-report measures,
risk assessments, 360-degree reviews, and internal audits
are all worth considering. Many firms view their hotline as
more of a helpline, offering employees the opportunity to
ask questions and avoid unethical behavior, as well as report
incidents. Update training in response to issues that crop up
to insure the firm against repeated violations and to adapt
training to the current areas of risk within your company.
“It’s not just a written program; it’s a living program,” Mike
Futch said.
Take action on ethical violations.
“We’ve had incidents that we reported to the Department
of Justice,” recalled one counsel, “and they’ve been very
appreciative, but at the same time they said, ‘You did the
right thing because we certainly might have had that on our
radar.’”
If a report comes in through the hotline or any other av-
enue, ensure that you have the resources to duly investigate
Ethics Programs
Continued from page 16