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The RF Ethics Program Part I: Tone at the Top and the RF Code of Conduct

The RF Ethics Program Part I: Tone at the Top and the RF Code of Conduct. With Joshua B. Toas, JD, CCEP Chief Compliance Officer and Assistant Secretary & Rich Agnello, Esq. Corporate Counsel. Submit Questions to: Email: studioa@hvcc.edu Phone: 888-313-4822. Learning Objectives.

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The RF Ethics Program Part I: Tone at the Top and the RF Code of Conduct

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  1. The RF Ethics Program Part I: Tone at the Top and the RF Code of Conduct With Joshua B. Toas, JD, CCEP Chief Compliance Officer and Assistant Secretary & Rich Agnello, Esq. Corporate Counsel Submit Questions to: Email: studioa@hvcc.edu Phone: 888-313-4822

  2. Learning Objectives • Recognize the value of a strong ethical culture • Identify both unethical and ethical cultures in action • Recognize consequences of both ethical and unethical cultures • Apply RF ethical principles

  3. Today’s Discussion • The value of a strong ethical culture • Key terms • Current Climate & Future Trends • Warning signs of Ethical Collapse • Tone at the Top • Movie Clip and Group Discussion • Code of Conduct and General Ethics

  4. Key Terms • Ethics • Integrity • Honesty • Truth • Culture • Ethical Culture

  5. Current Climate - In the News

  6. News – close to home

  7. Current Climate • In a recently released survey, what percentage of MBA students acknowledge cheating? 56%

  8. Current Climate • What percentage of employees have seen illegal or unethical conduct in the workplace? 76%

  9. Current Climate • What are the top three reasons employees don’t report bad or unethical conduct? 96% feared being accused of not being team players 81% feared nothing would be done 68% feared retaliation

  10. Future Trends • In a recent survey of high school students: • 74% cheated on an exam • 93% lied to parents • 78% lied to teachers • 37% would lie to get a job

  11. 7 Warning Signs of Ethical Collapse • Pressure to maintain numbers • Fear and Silence • Young ‘uns and larger than life CEO • Weak Board • Culture of Conflicts • Business Innovation • Moral Rationing

  12. Tone at the Top • Government and “the Public” want to see evidence that CEO’s are willing to “act responsibly, decisively, and aggressively” to remediate corporate wrongdoing • What is corporate integrity?

  13. Tone at the Top • Corporate Integrity • Ethics and core values of a business enterprise or business unit • Collective individual integrity of members of a group • Expectation that organizations have values, act consistent with those values, and make “the right choices” when public good is at odds with corporate self-interest

  14. Tone at the Top • Expectations of high integrity are more rigorously applied to personal acts of corporate leaders • Corporate leaders are being held accountable for the behavior of ALL • Standards of corporate integrity • How do leaders live up to the expectation?

  15. Tone at the Top • Articulate and Discuss integrity standards and expectations • Assess existing integrity systems • Develop new systems to define integrity • Develop high integrity leadership practices • Redefine consequence management practices • Appoint an integrity point person

  16. Tone at the Top • Leadership • Environment • Culture • Expectations • Consequences

  17. An Ethical Culture in Action • All employees: • Adhere to values • Follow the Code of Conduct • Adhere to laws, policies, and procedures • Report misconduct • Value & foster transparency and open communication

  18. Consequences of an Unethical Culture • One simple truth: • “A poor ethical culture breeds ethical breaches. Ethical breaches then often lead to legal violations. Too often accompanying both is financial collapse.” • Marianne M. Jennings Emeritus Professor of Legal and Ethical Studies in Business at ASU

  19. Glengarry Glenn Ross Video

  20. Small Group Discussion • Characterize the “tone at the top” as portrayed in this clip. • What ethical lapses could result from the “tone”? • Could the tone result in more than ethical lapses?

  21. Discuss Clip Share Feedback: • Characterize the “tone at the top” as portrayed in this clip. • What ethical lapses could result from the “tone”? • Could the tone result in more than ethical lapses?

  22. Governing Laws and Policies • Public Officer’s Law Section 74 (“code of ethics”) applies to RF employees • Basic Conflicts Rule: No RF Employee should have any interest, financial or otherwise, direct or indirect, or engage in any business or transaction or professional activity or incur any obligation of any nature which is in substantial conflict with the proper discharge of duties • RF’s COI policy includes NY’s rule and standards

  23. Governing Law and Policies • POL Section 73 • Section of law does not cover the RF • RF is voluntarily complying with the Gifts rules

  24. Governing Law and Policies • RF Code of Conduct has 10 Simple Expectations: • Act Ethically and with Integrity • Be Fair and Respectful to Others • Manage Responsibly • Protect and Preserve RF Resources • Promote a Culture of Compliance • Ethically Carry Out Sponsored Research Administration and Research • Avoid Conflicts of Interest and Conflicts of Commitment • Carefully Manage Public, Private, and Confidential Information • Promote Health and Safety in the Workplace • Follow the Law

  25. Code of Conduct • Integrity Tip: If in doubt, ask: • Is it honest? • Is it ethical? • Is it legal? • Do I feel comfortable with the decision? • Will it reflect well on me, my colleagues, the RF, and SUNY? • Would I want to read about it in the newspaper?

  26. Code of Conduct • Other general principles: • Follow the RF’s COI Policy • Must comply with the RF’s Fraud Policy and report suspected irregularity • Statement on Misconduct in Science • Do not make commitments without appropriate approvals • Honesty in reporting • Records retention • Be impartial when working with vendors

  27. Code of Conduct • The Code has general rules on: • Lobbying • Political Activity • International Trade Compliance • Export • Import • Anti-boycott • Speaking publicly and social media • External or media contact

  28. Ethics Scenario Small group discussion on a scenario SEE HANDOUT

  29. Ethics Scenario • List any Code of Conduct violations and explain how the conflict of interest policy could have been used to prevent this misconduct. • Is Woody guilty of violating the Code of Conduct? • What should Woody do when he learns of their plot? • What could Rebecca do to prevent this scenario?

  30. Ethics Hotline Call: 1.800.528.5745 www.compliance.helpline.com/rfusny.jsp

  31. Conclusion • Recognize the value of a strong ethical culture • Identify both unethical and ethical cultures in action • Recognize consequences of both ethical and unethical cultures • Apply RF ethical principles

  32. Questions? • Submit questions via the chat feature or via email at studioa@hvcc.edu • Follow-up questions can be sent to: • Compliance@rfsuny.org • RFLegal@rfsuny.org

  33. Next Session: Part 2 • Conflicts of Interest • Gifts • Nepotism • Fraud, Whistleblower, Ethics Hotline

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