Title defines report purpose and includes period covered in subtitle. REPORTED ETHICS CASES Annual Report 20– Report author includes name and title. Prepared by Susan Litzinger Director of Ethics and Business Conduct Report Distributed March 1, 20– Includes name of company to which report is submitted. Title page is unnumbered. Prepared for The Ethics and Business Conduct Committee CGF Aircraft Corporation Source: The Technical Writer’s Companion (3rd edition) by Gerald J. Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002) INTRODUCTION
Opening states report’s purpose. Subheads signal shifts in topic. This report examines the nature and disposition of the 3,458 ethics cases handled companywide by CGF’s ethics officers and managers during 20–. The purpose of this report is to provide the Ethics and Business Conduct Committee with the information necessary for assessing the effectiveness of the first year of CGF’s Ethics Program. Recommendations are given for the Committee’s consideration in planning for the second year of the Ethics Program. Ethics and Business Conduct Policy and Procedures
Background information is included. Effective January 1, 20–, the Ethics and Business Conduct Committee (the Committee) implemented Policy CGF-EP-01 and Procedure CGF-EP-02 for the administration of CGF’s new Ethics Program. The purpose of the Ethics Program, established by the Committee, is to “promote ethical business conduct through open communication and compliance with company ethics and standards. ” (CGF’s “Ethical Business Conduct”). The Office of Ethics and Business Conduct was created to administer the Ethics Program.
The director of the Office of Ethics and Business Conduct, along with seven ethics officers throughout CGF, was given the responsibility for the following objectives: • Communicate the values, standards, and goals of CGF’s Ethics Program to employees. • Inform employees about company ethics policies. • Provide companywide channels for employee education and guidance in resolving ethics concerns. • Implement companywide programs in ethics-awareness, education, and recognition. • Ensure confidentiality in all ethics matters.
Employee accessibility to ethics information and guidance became the immediate and key goal of the Office of Ethics and Business Conduct in its first year of operation. The following channels for contact were set in motion during 20–: 3 Source: The Technical Writer’s Companion (3rd edition) by Gerald J. Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002) • Managers throughout CGF received intensive ethics training; in all ethics situations employees were encouraged to go to their managers as the first point of contact. Ethics officers were available directly to employees through face-to-face or telephone contact, to managers, to callers using the ethics hotline, and by email. • The Ethics Hotline was available to all employees, 24 hours a day, 7 days a week, to anonymously report ethics concerns. Confidentiality Issues CGF’s Ethics Policy ensures confidentiality and anonymity for employees who raise genuine ethics concerns. Procedure CGF-EP-02 guarantees appropriate discipline, up to and including dismissal, for retaliation or retribution against any employee who properly reports any genuine ethics concern. Documentation of Ethics Cases The following equirements were established by the director of the Office of Ethics and Business Conduct as uniform guidelines for the documentation by managers and ethics officers of all reported ethics cases: • Name, position, and department of individual initiating contact, if available • Date and time of contact Details of methodology used are included. • Name, position, and department of contact person • Category of ethics case • Mode of contact • Resolution Managers and ethics officers entered the required information in each reported ethics case into an ACCESS database file, enabling efficient retrieval and analysis of the data. 4
Source: The Technical Writer’s Companion (3rd edition) by Gerald J. Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002) Major/Minor Category Definition and Examples Major ethics cases were defined as those situations potentially involving serious violations of company policies or illegal conduct. Procedure CGFEP-02 requires notification of the Internal Audit and the Law Departments in serious ethics cases. The staffs of the Internal Audit and the Law Departments assume primary responsibility for managing major ethics cases and for working with the employees, ethics officers, and managers involved in each case.
Examples of situations categorized as major ethics cases: • Cover-up of defective workmanship or use of defective parts in products • Discrimination in hiring and promotion Criteria used to differentiate major from minor infractions are included. • Involvement in monetary or other kickbacks from customers for preferred orders • Sexual harassment • Disclosure of proprietary customer or company information • Theft • Use of corporate Internet resources for inappropriate purposes, such as conducting private business, gambling, or access to pornography Minor ethics cases were defined as including all reported oncerns not classified as major ethics cases. Minor ethics cases were classified as follows: • Informational queries from employees • Situations involving coworkers • Situations involving management 5 Source: The Technical Writer’s Companion (3rd edition) by Gerald J. Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002) ANALYSIS OF REPORTED ETHICS CASES Reported Ethics Cases by Major/Minor Category CGF ethics officers and managers companywide handled a total of 3,458 ethics situations during 20–.
Of these cases, only 172, or 5 percent, involved reported concerns of a serious enough nature to be classified as major ethics cases (see Figure 1). Major ethics cases were defined as those situations potentially involving serious violations of company policy or illegal conduct. Figures placed in centered boxes. Title within figure box is centered at top. Major Minor Total Reported Ethics Cases by Major/Minor Category 20-Number of Cases 172 3,286 3,458 5% Major Category 95% Minor Category Each figure is identified with a title and number. Source: CGF Office of Ethics and Business Conduct. Figure 1. Major Ethics Cases
Reported ethics cases by major/minor category in 20–. Detailed findings are presented. Of the 172 major ethics cases reported during 20–, 57 percent, upon investigation, were found to involve unsubstantiated concerns. Incomplete information or misinformation most frequently was discovered to be the cause of the unfounded concerns of misconduct in 98 cases. Forty-four cases, or 26 percent of the total cases reported, involved incidents partly substantiated by ethics officers as serious misconduct; however, these cases were discovered to also involve inaccurate information or unfounded issues of misconduct. Source: The Technical Writer’s Companion (3rd edition) by Gerald J. Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002) Only 17 percent of the total number of major ethics cases, or 30 cases, were substantiated as major ethics situations involving serious ethical misconduct or illegal conduct (CGF “20– Ethics Hotline Results”) (see Figure 2). Major Ethics Cases 20-Unsubstantiated Cases Partly Substantiated Substantiated Total Major Cases 98 44 30 172 Figures are numbered sequentially. 26% Partly Substantiated 57% Unsubstantiated 17% Substantiated
Source: CGF Office of Ethics and Business Conduct. Figure 2. Major ethics cases in 20–. Of the 30 substantiated major ethics cases, seven remain under investigation at this time, and two cases are currently in litigation. Disposition of the remainder of the 30 substantiated reported ethics cases included severe disciplinary action in five cases: the dismissal of two employees and the demotion of three employees. Seven employees were given written warnings, and nine employees received verbal warnings (see Figure 3). 7 Source: The Technical Writer’s Companion (3rd edition) by Gerald J.
Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002) Disposition of Substantiated Major Ethics Cases 20-Employee Dismissal Graphs clarify report information. Employee Demotion Employee Written Warning Employee Verbal Warning Case Pending Total Substantiated Cases = 30 Case Currently in Litigation Source: CGF Office of Ethics and Business Conduct. Figure 3. in 20–. Disposition of substantiated major ethics cases Minor Ethics Cases Minor ethics cases included those that did not involve serious violations of company policy or illegal conduct.
During 20–, ethics officers and company managers handled 3,268 such cases. Minor ethics cases were further classified as follows: • Informational queries from employees • Situations involving coworkers • Situations involving management As might be expected during the initial year of the Ethics Program implementation, the majority of contacts made by employees were informational, involving questions about the new policies and procedures. These informational contacts comprised 55 percent of all contacts of a minor nature and numbered 2,148. Employees made 989 contacts regarding ethics concerns involving oworkers and 149 contacts regarding ethics concerns involving management (see Figure 4). Findings are reported in detail. 8 Source: The Technical Writer’s Companion (3rd edition) by Gerald J. Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002) Minor Ethics Cases 20-5% 30% Informational Involving Coworkers Involving Management Total Cases 2,148 989 149 3,286 65% Informational Situation Involving Coworkers Situation Involving Management Source: CGF Office of Ethics and Business Conduct. Figure 4. Mode of Contact Minor ethics cases in 20–.
Program effectiveness is analyzed in detail. The effectiveness of the Ethics Program rested on the dissemination of information to employees and the provision of accessible channels through which employees could gain information, report concerns, and obtain guidance. Employees were encouraged to first go to their managers with any ethical concerns, because those managers would have the most direct knowledge of the immediate circumstances and individuals involved. Other channels were put into operation, however, for any instance in which an employee did not feel able to go to his or her manager.
The ethics officers companywide were available to employees through telephone conversations, face-to-face meetings, and email contact. Ethics officers also served as contact points for managers in need of support and assistance in handling the ethics concerns reported to them by their subordinates. The Ethics Hotline became operational in mid-January 20– and offered employees assurance of anonymity and confidentiality. The Ethics Hotline was accessible to all employees on a 24-hour, 7-day basis. Ethics officers companywide took responsibility on a rotational basis for handling calls reported through the hotline. 9
Source: The Technical Writer’s Companion (3rd edition) by Gerald J. Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002) In summary, ethics information and guidance was available to all employees during 20–through the following channels: Bulleted lists help organize and summarize information. • Employee to manager • Employee telephone, face-to-face, and email contact with ethics officer • Manager to ethics officer • Employee Hotline The mode of contact in the 3,458 reported ethics cases was as follows (see Figure 5): • In 19 percent of the reported cases, or 657, employees went to managers with concerns. In 9 percent of the reported cases, or 311, employees contacted an ethics officer. • In 5 percent of the reported cases, or 173, managers sought assistance from ethics officers. • In 67 percent of the reported cases, or 2,317, contacts were made through the Ethics Hotline. 9% Mode of Contact in Reported Ethics Cases 20-5% Ethics Hotline 19% 67% Employee to Manager Employee to Ethics Officer Manager to Ethics Officer Source: CGF Office of Ethics and Business Conduct. Figure 5. Mode of contact in reported ethics cases in 20–. 10 Source: The Technical Writer’s Companion (3rd edition) by Gerald J.
Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002) Opening pulls together findings presented in report. CONCLUSIONS AND RECOMMENDATIONS The effectiveness of CGF’s Ethics Program during the first year of implementation is most evidenced by (1) the active participation of employees in the program and the 3,458 contacts employees made regarding ethics concerns through the various channels available to them, and (2) the action taken in the cases reported by employees, particularly the disposition of the 30 substantiated major ethics cases.
One of the 12 steps to building a successful Ethics Program identified by Frank Navran in Workforce magazine is an ethics communication strategy. Navran explains that such a strategy is crucial in ensuring that employees have the information they need in a timely and usable fashion and that the organization is encouraging employee communication regarding the values, standards and the conduct of the organization and its members (Navran 119). Outside source adds credibility.
The 3,458 contacts by employees during 20– attest to the accessibility and effectiveness of the communication channels that exist in CGF’s Ethics Program. An equally important step in building a successful ethics program is listed by Navran as “Measurements and Rewards,” which he explains as follows: In most organizations, employees know what’s important by virtue of what the organization measures and rewards. If ethical conduct is assessed and rewarded, and if unethical conduct is identified and dissuaded, employees will believe that the organization’s principals mean it when they ay the values and code of ethics are important (Navran 121). Findings presented in report are interpreted. Disseminating information about the disposition of ethics cases, particularly information about the severe disciplinary actions taken in major ethics violations, sends a message to employees that unethical or illegal conduct will not be tolerated. Making public the tough-minded actions taken in cases of ethical misconduct provides “a golden opportunity to make other employees aware that the behavior is unacceptable and why” (Ferrell and Gardiner 129). 1 Source: The Technical Writer’s Companion (3rd edition) by Gerald J. Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002) Recommendations are offered. With these two points in mind, I offer the following recommendations for consideration for plans for the Ethics Program’s second year: • Continuation of the channels of communication now available in the Ethics Program • Increased financial and technical support for the Ethics Hotline, the most highly utiltized mode of contact in the reported ethics cases in 20–
Author emphasizes what should be done based on report’s findings. • Dissemination of this report in some form to employees to ensure employees’ awareness of CGF’s commitment to uphold its Ethics Policy and Procedures • Implementation of some measure of recognition for ethical behavior, such as an “Ethics Employee of the Month,” to promote and reward ethical conduct To ensure that employees see the value of their continued participation in the Ethics Program, feedback is essential. The information in this annual review, in some form, should be provided to employees.
Knowing that the concerns they reported were taken seriously and resulted in appropriate action by Ethics Program administrators would reinforce employee involvement in the program. While the negative consequences of ethical misconduct contained in this report send a powerful message, a means of communicating the positive rewards of ethical conduct at CGF should be implemented. Various options for recognition of employees exemplifying ethical conduct should be considered and approved.
Continuation of the Ethics Program’s successful 20– operations, with the implementation of the above recommendations, should ensure the continued pursuit of the Ethics Program’s purpose: “to promote a positive work environment that encourages open communication regarding ethics and compliance issues and concerns. ” 12 Source: Writing That Works (7th edition) by Walter E. Oliu, Charles T. Brusaw, and Gerald J. Alred (Bedford/St. Martin’s, 2001) WORKS CITED References appear on separate page. CGF. “Ethics and Conduct at CGF Airlines. ” 5 April 1998. CGF. “1995 Ethics Hotline Investigation Results. ” 5 April 1998. . Ferrell, O. C. , and Gareth Gardiner. In Pursuit of Ethics: Tough Choices in the World of Work. Springfield: Smith Collins, 1991. Kelley, Tina. “Corporate Prophets, Charting a Course to Ethical Profits. ” The New York Times 8 Feb. 1998: BU12. Navran, Frank. “12 Steps to Building a Best-Practices Ethics Program. ” Workforce Sept. 1997: 117–122. 13 Source: The Technical Writer’s Companion (3rd edition) by Gerald J. Alred, Charles T. Brusaw, and Walter E. Oliu (Bedford/St. Martin’s, 2002)