One Month to a More Effective Compliance Program Thru Culture: Day 6 - Attributes of a Toxic Culture

Thomas Fox - Compliance Evangelist
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Corporate culture is finally being acknowledged as a key ingredient in a successful business, particularly one that operates ethically and in compliance. But what are some indicia of good culture and more importantly what are some indicia of a toxic culture? A recent article in the MIT Sloan Management Review provided some guidance. In Why Every Leader Needs to Worry About Toxic Culture, the authors posited that by pinpointing the elements of toxic culture in a company, its leaders focus on addressing the issues that lead employees See more +
Corporate culture is finally being acknowledged as a key ingredient in a successful business, particularly one that operates ethically and in compliance. But what are some indicia of good culture and more importantly what are some indicia of a toxic culture? A recent article in the MIT Sloan Management Review provided some guidance. In Why Every Leader Needs to Worry About Toxic Culture, the authors posited that by pinpointing the elements of toxic culture in a company, its leaders focus on addressing the issues that lead employees to disengage and quit. These ideas have significant importance for the compliance function as it navigates corporate culture, both in assessing and improving it.

Moreover, the Chief Compliance Officer and corporate compliance function were identified in the 2023 3 Evaluation of Corporate Compliance Programs as the keepers of institutional justice and institutional fairness. This means recognizing and then preventing a toxic culture from spreading and infecting your entire organization squarely in the compliance wheelhouse. The article lays out key red flags for every CCO and compliance professional to look for in assessing culture. Finally, for any company with a toxic culture, the chances are much greater to be defrauded by its own employees or to defraud others through bribery and corruption by violating such laws as the Foreign Corrupt Practices Act (FCPA).

The authors identify behaviors that they call “the Toxic Five attributes”, being “disrespectful, noninclusive, unethical, cutthroat, and abusive – poison corporate culture in the eyes of employees. While organizational culture can disappoint employees in many ways, these five elements have by far the largest negative impact on how employees rate their corporate culture and have contributed most to employee attrition throughout the Great Resignation.” As a CCO or compliance professional you need to be on the watch for them and take steps to remedy them if you see or hear about them.

Three key takeaways:

1. Are the attributes of a toxic culture present in your organization?

2. The 2020 Update to the Evaluation of Corporate Compliance Programs mandated the compliance lead this effort.

3. Does your organization have abusive behavior? See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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