How does ethics and compliance play its part in creating company culture? And how can organizations establish a shared vision for ethics and compliance within their teams?

Speaker A: Hello and welcome to this episode of Steps to Change, the podcast where we explore learning and development topics, organizational behavior change and practical ways to inspire people to act differently and to support organizations with strategies for addressing their challenges. On this episode we're discussing the question, how do ethics and compliance play their part in creating organizational culture? And how can organizations establish a shared vision for what good looks like when it comes to ethics and culture in their day to day and earth interactions? Our guest on this episode is Tim Graveny, the ethics and compliance officer and freedom to speak up guardian at HCA uk. Welcome Tim, how are you?

Speaker B: Hello Alan. Um, thank you very much indeed. It's lovely to be here. Thank you for the invitation. Um, yeah, I'm doing okay. Thank you very much indeed.

Speaker A: So Tim, for the listeners out there, tell us a little bit about yourself, uh, your background in the ethics and compliance space and anything else you think is worth knowing before we dive into the conversation.

Speaker B: Well, I started out at university doing law and politics and imagining that I would um, have a career either as a barrister or as a diplomat or as an MP even at one stage. Uh, uh, but I started out at Deloitte. I accepted a paralegals job at Deloitte because I had nothing really else to do um, at that time. And 17 years later, having found steps along the way and a wife, I decided that, that ethics and compliance was where it's at for me, fell into the career a little bit. Um, I had a break for a year and a half um, after Deloitte where I was a house husband and uh, dealt with ethics and compliance uh, in another way and then found my way to healthcare. Um, and so I'm working now as the ethics and compliance officer at HCA Healthcare in the UK which is a UK division of an American company. Um, and in that role I've got responsibility for the speaking up program which is the exciting part of ethics, but also um, the anti bribery and uh, other regulatory compliance that we have across our business. As a private healthcare operator we need to be very transparent. That's the key for us, uh, with prospective patients. Um, and so that's how I became um, I became excited by compliance about 20 years ago and haven't really lost the buzz.

Speaker A: Thanks for that background Tim and I really love to hear that sort of organic development of your career into this space. Right. Because uh, one of the things we are going to talk about as we go into the topic now is that ethics and compliance can be seen as like the scary no fun police part of the business and that's one of the things I want to unpack with you. So for you to fall in love with it is really great. So I'm excited for you to share that passion you have for it and why it's useful in helping, uh, create a shared vision and culture, uh, and the challenges it uh, can face in businesses. So um, yeah, Tim, let's get into it. So, um, you know, uh, as I was saying, that idea of ethics and compliance can seem like the kind of finger pointing or you're going to get in trouble aspect of a business. Um, is that the case for it or is it just getting a bad rap? And why should people really care about ethics and compliance in a business?

Speaker B: Well, I think to describe it as, um, the no fun police or scary or whatever words you've just used there, which are very common, uh, you know, does it a disservice. And, and of course I would say really ethics and compliance, although I would like to discuss what those terms are. But taken generally in the vernacular, so to speak, I think they're about having fun, but in the right way. M. Uh, if fun is what we're in it for, it's about sort of setting the rules and understanding, you know, what to do when, when we get to the edges of those rules. Um, that doesn't seem to me to be um, a uh, no fun engagement at all. And Certainly over now, 25 years working in this space, uh, one sees uh, ebbs and flows and tides and it's exciting and keeps you on your toes as you respond to those in a way that really drives the business forward. And to the latter part of your question, um, I think a company that uh, does things the right way, that is true to its values, in particular, uh, that that quite nefarious concept sometimes of integrity is likely to be one which attracts people like you and me, Alan, and then our kids and the people that we can influence and in that, in that way is a little bit more secure through for the generations. So I really think it's absolutely fundamental to doing good business.

Speaker A: Absolutely. You know, and I was being a bit of a devil's advocate at the start there with the way I positioned that question. Because I think, you know, when we, in the work we do and work we've definitely partnered with you on, Tim, you know, when you start doing the research around, you know, what is your viewpoint on ethics and compliance with the general population, sometimes that can be some of the sentiment people have towards it. But what I really like about how you positioned it there is it's really about establishing those rules of engagement, those shared, um, uh, that structure that allows us to understand how we need to operate as good citizens within the organization. So that actually you know, that you're, you're operating in a way that's compliant, um, but also aligned ethically, uh, and living the values of the organization. So it's really about giving that shared reference point that everybody understands the role that they can play.

Speaker B: I would certainly agree with that. And I think actually that that's quite a neat way for me to make quite a key point, which is that ethics and compliance mean to me all things to all people. So there are the obvious challenges. And you know, I would imagine that many of the people listening to this podcast will be in roles similar to mine. And so it's very easy sometimes to hear the negative tone about ethics and compliance. And you may find me rather boring by the end of the episode because, uh, I think you may, if you ask the right questions. Anyway, you'll find that I'm very excited by it and want to talk in different terminology and often reverse the polarity of the question, so to speak. But I think it is important to note that ethics and compliance are not the same thing. Um, and I think that they're all things to all people, which, okay, it does mean that you're on the hook. Sometimes if your organisation is in the press for a bad reason, people will look at you as the ethics and compliance officer and think, well, that must have been something to do with you. But actually as time goes by, I find this ah, increasingly easy to do. You are also allowed to tailgate the great stuff that your organization does. So in mine right now, the, um, environmental compliance, for example, ah, and sustainability goals. And when I think about ethics and compliance and taking those two terms generally, I feel it's all about the reliability of your organization and are they reliably true to the mission statement and the values and the goals that you espouse, no doubt in your codes of conduct and in your other policies. And if your organization is reliably compliant or has reliable ethics, then I really think that you're onto something extremely positive.

Speaker A: So, uh, one thing I want to kind of touch on as we start to drill this down into how can organizations create a shared understanding of, um, the ethics and the values and the compliance requirements within an organization? You've mentioned you've been in this space for um, over 20 years and things change. Things aren't set in stone. People's values change generationally or there's different viewpoints across different regions of the globe. So I guess trying to come up with my question on the fly here. How do you manage shifting viewpoints in a role that is trying to establish good citizenship behavior, if you will? Um, and people maybe come at you and go, well, I don't view it that way. These things change. And I have a different viewpoint.

Speaker B: I don't align with that to be slightly Pollyanna esque about the, the start to that response when you say people's values. People do people's values really change, Alan? I'm not so sure that they really do. Um, and certainly organizations are very, very far away from accepting anything other than rules based, policies based approach. I don't think that people's values are changing. And so I think my first response is to remind people that what is good and right is good and right, and you know perfectly well what they are. Um, there are some challenges right at this very moment, of course, as we know, on a sort of macro scale. But again, to the audience members here, I would say, well, let's shut that out. Shut out the outside. Okay, be aware of it. But. Well, actually there are many people in my circle, including me, who though lovers of, uh, podcasts like this Alan, um, but about politics in the UK and in the US Want to shut it out. We almost want to shut it out right now. So whether or not you can do that with your podcasts, I would encourage you to sort of shut it out at work and just remind yourselves that what is good is good. Um, and acting with. Get a bit CS Lewis about the definition of integrity here, which means all things to all people again, but if it is about doing the right thing when no one's watching, um, then you know perfectly well that that is today what it was 10 years ago. And it will be, by the way, in 10 years what it is today as well. That is hard to do to shut out the outside. I know. And I'm working in an organ which is across continents and has an American influence, for example. It can be tough. Uh, but how do you internalize it? Well, I think if truth matters to you, um, and transparency, as I've already said about my company's philosophy of transparency and truth mean something to you? Um, be on it. Be honest. Um, and by the way, if truth and transparency don't mean something to you, then why are you even listening to this podcast? Why are you working in ethics and compliance? Why are you interested by ethics and compliance? Go find something else to do. You know, become a podcaster. Alan.

Speaker A: Fair. Well said, Tim. Absolutely. Well said. Yeah, I love that. So, um, let's now move into, um, this idea of how you actually, uh, create that shared value and viewpoint in organizations. Right? So, you know, as a, as an organization, you will have come up with your, your, your values, your ethics, your rules of engagement. Um, so how do you actually make that live, uh, and get a collective shared viewpoint on what that is for people in the business, in your experience, Tim?

Speaker B: So I think, for a start, I would challenge people, even with this very basic thought, um, when we talk in questions like that, about having shared values, values across the company that everyone is aware of. Are they, Are they really aware of what your values are? Um, I can articulate my firm's mission statement, and I know my firm's values because I'm responsible for, you know, nurturing them and very proud I am to do that. Um, but firstly, does everybody know those values? Um, and know what that. What the code of conduct states? But then secondly, what does it actually mean to you? And I think that second thing is very important for all of us. What does it actually mean to you to work in an organization that acts with integrity and acts in an ethical way? Always. Each individual should, in a healthy organization, be allowed a modicum of a gray area, you know, so long as they know how to, how to police that themselves. So I don't think you're looking for a one size fits all approach when it comes to ethics and compliance. And I think even if you tried that, there would be a bunch of people in the room who would throw the three examples of where it didn't go. Right. Rather than the three who would hear you and say, yes, that endorses my view. So how do, how do you get a best fit that allows everybody the freedom to be who they are whilst not compromising, you know, the direction of travel for the company? Well, you need to be, um, you know, aware of the resources at your disposal. And if you're privileged enough, as I am, to be in a role where you can sort of set the direction of travel, then you've got to be in the right committees, you've got to be in charge of the right things. You've got to know when to play second fiddle, too. Um, you need your leaders on board. Absolutely. But you need to be taking every opportunity you can, I think, to publicize what you're doing as the ethics and compliance representative, not only to articulate what the rules are, but to help people understand why the rules are the rules that they are. But now our strap line is enabled transparent and true. Um, and so that means that our people are enabled, um, by good policy for example, or by talking with me to understand what the rules are, um, that what we disclose is transparent, um, so that we don't hide information on websites, for example, um, that we're very clear about what it is that we publish and then true should stand self evidently. But I don't think does quite right at the moment. But what is true is true. If I disclose that we paid a doctor £100 for something, but we in fact paid him or her £1,000, that is wrong and it is not right and there is no circumstance in which that is right. Keystroke error perhaps, but on the example I've given, but we know what we have done and we must disclose it, I think truthfully. So keep it pretty simple. Use every opportunity you have to set training agendas as well. Go and meet the people. Find if you can, we're going to talk about speaking up champions. I think I've got a network of speaking up champions that help me with that particular, uh, role. But uh, yeah, just see if you can see who you can influence and then influence them with. Kindness, I suggest is quite key, um, because people do like kindness from their ethics and compliance officers.

Speaker A: And you know, the training aspect just uh, want to pick up on that because I do want to dovetail this into Speak up in just a moment. But one of the things around um, obviously that you're aware of Tim, and the listeners will be aware of is that steps, we're really curious about the behaviors of these things, right? So we can write all this stuff out and we can say this is what this means. There's our three words. But then what's a really interesting aspect of training that we have leaned into our experience with Deloitte, um, and probably in future programming potentially is, you know, when you, you ask, you go, okay, these are, these are the, these are the ways we behave. But then when you wrap that up into everyday situations, right of, oh, I'm in this type of meeting and somebody is saying this, or I'm now at a, I'm now out with a client and they're behaving in a way that isn't aligned with our values, what do I do? And you ask people in a room, how would you, how would you show up in this space? You're going to get as many different opinions as there are people in the room. And I think that's a really fascinating aspect that, that training part that needs to come in because you know, we're all human beings and nobody's perfect. But we need to give people an opportunity to explore these challenges before they get into them so they can prepare themselves to behave in a way that's going to be, you know, more in line with what's the expectations are.

Speaker B: Yeah, mhm. I would certainly agree with that. I love the way that Steps in particular, I know other companies are available, but I love the way Steps uses drama. Um, and you know, it was a privilege to work with you all um, many years ago at Deloitte. And it is the same with HCA as well. So what is great about the Steps program actually is that we are in the privileged position of actually just watching and we can all talk a bit about it afterwards. So I think I love working uh, with Steps and in particular that very unique way in which you create learning around this space, uh, which as you correctly identify unquestionably has given me, but also the people that I'm privileged to influence in some way, the opportunity to prepare in advance, Alan, as you rightly say, for situations that can be very difficult indeed.

Speaker A: So I'd love to hear your thoughts on, you know, why Speak up culture is important for supporting compliance and ethics and keep bringing that positive spin, Tim, because I think that's a really wonderful aspect to really encourage people. This is a, ah, you know, uh, a good thing, right?

Speaker B: So it is a good thing speaking up. Um, you know, I, I don't quite know what it looks like when it's done badly to be fair. But uh, but I'm going to say, at least when it's done well and actively, it is something that will not only improve the situation for the person who's spoken up, but will bring the listener a great deal of happiness as well. And in that way I think absolutely reinforces um, the thread through the organization that speaking up matters because they tell their peers and their colleagues and in that way we can work with hr, by the way, very hand in glove with hr. We can work to make the situation better for other people as well.

Speaker A: M. Yeah, I love that because once you're aware that there's an issue, then the positive aspect is that we can work together to try and solve this. Right, smooth things over or rebuild that trust or whatever it is that you're trying to solve for. Um, uh, but I guess I'm just curious around. For example, we've worked quite a lot in the finance space, um, uh, and there have been challenges in organizations, um, in the finance space. Where someone might be managing a trade in a way that isn't fully compliant from a regulatory, you know, perspective, but also from a values perspective within the organization. But then people know, but they don't say anything because they go, well, you know, it is what it is and that's just kind of how it works. So I'm curious, Tim, you know, in your view, what might keep people from speaking up when they can absolutely see that something's not right? And is there any tips beyond what you've already shared for someone in your role or within an organization to kind of help address that? Because, you know, by not speaking up, it can have really big impacts. It can have, you know, huge, uh, financial impacts. It can have, um, uh, societal impacts in the way that you're viewed. Right. Damaging news in the press, et cetera. Um, yeah, I'll throw that, that question over to you just to get your thoughts on it.

Speaker B: Again, it's the example you gave there of somebody, um, you know, not doing a, not listing a deal in the right way. The detail doesn't matter. Um, is a really interesting example, Alan. And you've, I think, deliberately pitched it at the sort of higher pitch. So to spit higher register. That's tough. That's a really tough situation for me or anybody to deal with, to be honest. And so my first, um. Uh, well, I'm going to use this word maybe only a couple of times, but the first barrier to speaking up I think can be the serious of the incident. And actually, you know, when I, when I list in my mind the barriers that I now go on to identify, seriousness isn't necessarily one of them, but you're right that it should be. Um, the more typical barriers to speaking up include, um, the fact that, you know, the expectation that no one will listen. I've partly addressed. Um, another is that I will suffer detriment for speaking up. And it's a word that people. Be very familiar to a number of people, um, that my career in some way will be, um, sabotaged, um, by Speak Up. Indeed, my, my existence of the company, even existentially might be at threat if I do this. Um, another is that, that I often hear, which people might sense some frustration about is, um, somebody else has spoken up about this, but nothing happened, to which the answer is almost always, well, either they didn't speak up actually, despite what they told you, or else certainly, you know, they didn't speak to me. Um, you know, so, so I, I can help. I, I'm. I, I know I can still help. So so those are some of the, so those are some of the, the key, the key barriers to speaking up. But, but I am going to launch into this now because the answer to that is, is as I've, I've said to, to the National Guardians office as well. And, and perhaps some people have heard me speak about this. But, but for me, um, I think it's much easier and certainly much more productive for everybody in the organization to invert that question again and actually look at those same barriers to speaking up as portals for speaking up. And I'm not an astrophysicist, as is very clear from my cv, which I articulated earlier. Not an astrophysicist, guys. So apologies for using that word, um, uh, colloquially. Um, but what I mean by that is simply that if, if let's say the chief exec doesn't listen is identified typically as a barrier to speak up in your organization. If you can prove that the chief exec listens and is interested and then takes some action, well, you know, that all of a sudden acts as a portal, you know, a gateway to further success for your program in the organization. And I can say the same thing as well about all of those other barriers to speaking up as well. In particular the one about taking no action, um, or nothing will happen as a result of this. And uh, you know, people like me wrestle all the time with confidentiality. I say we wrestle with it. We love confidentiality. It's very, very important. It's very, very important that we protect it. Um, but identification of situations in the telling of stories which you and I both love and have loved together for many years, um, if the telling of stories somehow identifies somebody who hasn't given consent to um, you know, for their story to be told, then that obviously is something that you must not risk at all. So a fun challenge again, but a challenge nonetheless is to celebrate in a different way or in a very careful way those situations where speaking up has really resulted in a change. And if you get that right again, for example in your annual training, for example in dramas or in the discussion points after dramas, that steps has helped you to convey to your, to your people. Oh my goodness me, then, then you've got people coming out of the room saying m hang on a minute, I didn't realize that I had had that impact. Or that's very exciting because that's the sort of impact we need around here. Um, and so you, you, it's a self fulfilling, a virtuous circle if you like, but, but you're so self fulfilling at Every stage that you improve things along the way. So, so I would, as my number one takeaway, speak positively about Speaking up.

Speaker A: I love that. And I'm sure the astrophysicist community won't mind the analogy, uh, of the portal. They'll allow it, I think, uh, because that very clearly illustrates the point. And I want to, uh, I don't know if this is a reach too far, but part of that portal aspect that you talk about, where people can go, is that connected to the Speak Up Guardian concept? Um, because I'm just curious for our listeners, tell m us a little bit more about that and how you create those Speak Up Guardians or champions or what they may be. And uh, so maybe they can take that away to their organizations.

Speaker B: Yeah, absolutely. Well, those of you who are privileged to work in healthcare may know about the National Guardian's office, um, indeed across other sectors as well. So, uh, we borrow much of what we do from the National Guardian's office. And that's your first link if you're curious about this question. Um, but they're Speaking Up Champions. Well, I can't. Yeah, we've got an organization here of about, about. I've got about seven and a half thousand people at uh, the latest count to look after and I'm doing compliance as well. So this is part of my ethics role. So I've only got a small part of my time, ah, available or a limited part of my time. It's not small, but it is limited by other things, uh, available for ethics. And so I need help ultimately, Alan, that's the first thing. And in my organization we run a number of, um, hospitals, um, and so across a number of locations, each by the way, with their own culture, each team even with its own culture. A, uh, topic for a different guest, though I'm privileged to know several who've achieved wonders in that situation. But I need help. And so we launched this Speaking Up Champions program here on March 23, 2020. It's grown since then. And so we now have very nearly 50 speaking up champions across our organization. We aim to have one for every 150 members of staff, which will answer a question that I know a number of people will be thinking. And they receive, as I said earlier on, actually they receive a little bit of acting training from me, um, um, and my support always. And we together celebrate that. HCA makes me available for them whenever they need me, but also gives them an opportunity to lead themselves. Of course, they're often more junior members of staff, partly because it is perceived that Senior members of staff won't listen. Um, but, but we give them leadership responsibilities with, with this role as well. And, and so, and we meet regularly to, to share very carefully some of the successes. Ah, as I've indicated before. And, and really it's just a great privilege to know these people, firstly, of course, as speaking up champions. But then, you know, then as they move on and do other things with their careers, sometimes here, sometimes in other organizations, you're lucky enough to stay in touch with them and you find that very soon they become your friends and, you know, can help you and all those other things in life as well. So it's a community of kind. People try to do their best. Um, and, um, that, that, that is very helpful right now in reinforcing some of the, you know, some of these very positive messages that we are very much trying, um, to embed in this organization and wherever we can beyond brilliant.

Speaker A: And, and Tim M. Any last words of wisdom before we finish, uh, out the episode?

Speaker B: I don't think you've had a first word of wisdom yet, have you? I think that's unproven, but I'll give it another go. I'll give it a last go.

Speaker A: You do yourself a disservice.

Speaker B: I think the key thing that I would like to say here, which knits everything together, and you've heard it echoed already, but I'll do it one last time. Never stop talking to other people. I think I'm pretty good at my job. I really hope so. Um, and in moments where I get thoroughly reflective, I actually allow myself these days to pat myself on the back occasionally. But I don't know everything. I really don't. In fact, I barely know anything at all. And even if I think that I know quite a bit, I guarantee that if I actively listen to the perspectives of others, then I'm going to make. I'm going to be even better in my role. And you'll never know. You just never know when it's going to be important. And so just very quickly, for example, I attended one of your sessions recently on multi generational working. Uh, and in the discussion there was a concept of reverse mentoring with which I'm familiar enough, but then pairing. And I am working on that this week I've come into work and I'm actually working on what we can do around that. And that's because I have the privilege of listening to it, albeit with steps, but I have the privilege of listening to it from somebody else. So keep listening. Keep listening.

Speaker A: Well, very wise words, Tim. And unfortunately, that's about all the time we have left for this episode. So thank you, Tim, for joining us. It's been a really engaging and thought provoking discussion. Do you want to let the listeners know where they can connect with you on socials or LinkedIn if you want to share that information?

Speaker B: Yeah, absolutely. Well, there aren't too many, um, tim gravenies on LinkedIn. The other is more famous than I am, actually. And if you, if you know your cricket, you might know something about him. But, but, uh, I'm, I'm the younger of the Tim Graveneys and my profile picture is as, as, as all good profile pictures on LinkedIn is 15 years younger than you see me today. So please do find me on LinkedIn. And I'm delighted to, to offer you my, my company's email address as well, which is Ethics and Compliance. All one word there@hcahealthcare. All one word there.co.uk that will come straight through to me and I would be delighted to share any thoughts with you and to take any discussion points forward with you, including, of course, challenges.

Speaker A: Well, Tim M, thank you for that offer and listeners will put all that stuff in the show notes as well, so you can have access to that. And thank you for joining us on this episode. If you'd like to know more about Steps and Steps to Change, make sure you visit our website, find us on LinkedIn or sign up to our newsletter. Again, we'll put all those in the show notes. If you're interested in how Steps could partner with you or your organization to support your needs, you can send us an email or fill out the form online at www.stepsdrama.com. is there a subject area you'd like to hear us explore? If so, reach out to us via the email or on our socials and let us know. As always, thank you to our production team. We couldn't do this without you. I am your host, Alan Liedtke, and we look forward to you joining us on the next episode. Until then, remember, you too can see it, own it, change it and live it.