COMPANY: Deloitte & Touche USA
PR
AGENCY: Deloitte Services
CATEGORY: Corporate Social Responsibility
BUDGET: $300,000
TIMEFRAME: September 2004-ongoing
CSR WINNER: Business Ethics Communications
When global financial giant Deloitte & Touche was
searching for a concept to personalize its internal "Personal
Integrity, Public Trust" program, designed to demonstrate the
company's commitment to ethics and integrity, it came up with the
idea of a poster instructing employees to "ask their mothers." It
featured a mom, standing with her arms folded alongside the
headline "The Mom Test." The copy read: "Here's a good test when
you're faced with a difficult ethical decision. Ask yourself what
your mom or dad or anyone else whose opinion you respect would
say."
In a world awash in financial scandals, fraud and ethically
challenged CEOs, perhaps others in the financial sector should heed
this advice. And it's no surprise that companies like privately
held Deloitte & Touche are setting up internal controls and
guidelines to negate the likelihood of future ethical lapses.
"One group in our organization consults with clients about their
ethics programs, and we realized we should do the same for
ourselves," says Gwyn Blanton, program director/ethics and
compliance at Deloitte & Touche USA. "We've always had a code
of conduct, and ethics is part of our culture, but with what was
going on in the marketplace, particularly with the Sarbanes-Oxley
Act, we recognized we needed to renew our commitment. We wanted to
take what was implicit and make it explicit, and more relevant on a
day-to- day basis."
If it's a truism that the cobbler's children have no shoes, then
Deloitte was determined not to go unshod. "Someone from client
services, who'd implemented an ethics program for 10 years, applied
it to what we were doing here," Blanton says. "I'd been in
marketing for six years and the concepts we used externally we
applied internally. We made Deloitte our client."
Previously, Deloitte had a code of professional conduct and
ethics as part of its career training, but there was no dedicated
program to address the issue.
In the two years prior to 2004, Deloitte had conducted a
cultural assessment of its organization, and it did extensive
internal interviews. "Some corporations need to have something
major happen, but we decided to be proactive and apply to ourselves
the same internal controls and standards that were being applied to
a publicly traded company," Blanton says.
Planning began in March 2004. Blanton and her team -- including
an internal-communications manager, the head of the
graphics/production studio and an outside creative consultant --
quickly realized the need for a multi-media approach. "We felt it
was important to use hard copy because e-mail is used so much,"
Blanton says. The strategy was to have the message come from
different leadership areas within the firm, and then to slowly roll
out each part of the program.
The result was a four-part program consisting of a "Code of
Ethics and Professional Conduct," a practical guide; Ethics in
Action, a two-part training program; an Integrity Helpline; and the
appointment of a chief ethics and compliance officer, Harold
Tinkler, to oversee the program. Launched in September 2004, it
included voicemail from the CEO of the firm and an introductory
video of Tinkler. "We wanted everyone to know who he is," Blanton
says. "We wanted people to feel 'OK, I can tell this guy
anything.'"
Scheduled for a18-month period, the mandatory classroom training
was important. "In training, we talk about ethical dilemmas and how
you ask questions that help you determine what your next step
should be--hence the idea of the poster, reinforced by a follow-up
e-mail," Blanton says.
But if Deloitte was scrupulous about its efforts to re-educate
employees, it also did not want to be seen as tooting its own horn.
"We didn't want to use this as a marketing tool or promote it to
clients, because we need to be promoting this for the right
reasons," Blanton says. Deloitte did, however, post its code of
conduct on the company's external Web site, and make it available
to existing and potential clients, should they choose to look. "We
have a commitment not to use this as a point of differentiation,"
Blanton says, "and we believe all public accounting should operate
on this level."
When it came to dealing with the media, the philosophy was the
same. "For the same reason, we also don't promote it to media,"
says Cindy L. Morgan-Olson, senior manager/executive
communications, national public relations at Deloitte Services LP.
"It would look self-serving, as if we'd created it for the wrong
reasons when it was created as a guideline to help people make hard
decisions. We've conducted a few key interviews -- with
Compliance Week, for example -- and other, similar
publications that address compliance issues like Sarbanes-Oxley.
That's a good use because of the audience, but in a mass media PR
sense, it would look gratuitous."
Other PR initiatives involve Tinkler speaking to universities
and participating in panel discussions. "That's an instance of
public relations guiding young people coming down the pike and
treating ethics as a way of life," Morgan-Olson says. "There's
growing interest in an ethics curriculum as part of a graduate
program. Universities are likely places to have these
conversations, because they will go out and create similar
programs."
Deloitte & Touche is not alone in tending to its own ethics.
Most accounting firms now have similar programs. "We talk about
helping to maintain the public trust, which must not be taken for
granted," Blanton says.
Thus far, Blanton says, the program has been well-received
internally. "Because we use a more creative approach, using visuals
and headlines, it's become water-cooler conversation," she says.
Deloitte will evaluate success based on the number of calls to the
Helpline, and in participation in the training programs and
awareness surveys. "We also look at the nature of the calls,"
Blanton says. "We want a higher ratio of people asking questions,
as opposed to making reports. That's an indicator that people are
looking at things as the issues come up, rather than waiting and
letting them develop into a real problem. One benchmark is that, so
far, over 60% have completed the online training program, motivated
by our communications campaigns."
Deloitte did a baseline survey last June, looking at attitudes
and opinions about ethics within the organization, and it's now
conducting surveys and focus groups across the country. "We'll
continue to develop e-mails and posters," Blanton says. "Our goal
is to have everyone through the classroom training by the end of
this calendar year."
What did Blanton learn from the exercise? "The biggest Aha! for
me is that internal communications can have a profound impact on
moral and the culture of an organization," she says. "I had always
done external communications until I took on this role. It's
sobering and frightening for me."
According to Morgan-Olson, "We're giving them the 'how.'
Everyone in this profession says, 'go be ethical,' then they
scratch their heads about how to do it. This gives them a road
map."
Contacts: Gwyn Blanton, 203.761.3015, [email protected];
Cindy L. Morgan-Olson, 203.761.33015, [email protected]
Communicating On Several Levels
Implementing the Deloitte & Touche ethics program at every
level of the organization was a mammoth task, what with more than
50 offices and 32,000 employees. And because of the matrix
structure of the company, which has 28,000 partners/owners with a
variety of criss-crossing leadership roles, it took an enormous
amount of attention to detail to reach every leadership group. "We
had to make sure we included everyone," says Gwyn Blanton, program
director/ethics and compliance at Deloitte & Touche USA.
"You've got to know it in your bones, because it's not mapped out
anywhere."