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Corporate Compliance Insights
Home Ethics

How Does a Company Assess its Culture?

The Basics of Corporate Culture, Part 4

by Jay Rosen
October 9, 2019
in Ethics, Featured
stack of colorful question cards on blue background

Is it possible for a company to get a true read on its own culture? Jay Rosen discusses what to consider and when engaging an independent third party might be the best option.

How can a company assess its own culture? First, we should consider whether the company is able to perform a self-assessment of its own culture or whether it should engage a truly independent professional to do the assessment.

Both approaches are valid, but each has a different focus. The self-assessment is really more like an ongoing monitoring. In this scenario, a company has the responsibility to monitor its own workforce culture literally on a day-to-day basis. That ongoing monitoring and oversight is critical to being able to manage what is a very normal ebb and flow of the culture in an organization. Cultures are dependent on people, and people come and go in companies, which can influence the culture. Additionally, market and financial stress can influence the culture and what happens within a company. These are all things a company should track and monitor.

When an external independent monitor comes into the picture, a company can generate a broader picture of where its culture exists.

Many employees are more willing to open up to an independent outsider rather than someone in their own organization.

Sadly, many leaders do not know their own workforce as well as they should, because they do not get out of the office and interact with them. Such leaders tend to only rely upon filtered information and reports, which do not necessarily represent the true culture or even the way people might feel in their jobs. They are unfortunately depending on hope and not the facts on the ground as they might be shared with an independent, outside assessor.

Some of the ways to assess an organization’s culture include employee surveys, conversations and visits to field operations. Surveys can be useful tools to take the temperature of what’s going on in the company, but often there is a missed opportunity to include specifically targeted questions about culture and the company’s ethical posture. These need to be two-way conversations to get a true understanding. Often, leaders don’t understand how they’re being perceived and whether employees are receiving mixed messages.

Another key area to assess is whether the company has created a true speak-up culture.

Is there a comfort level for employees to raise issues, questions or identify misconduct up through their managers, or is there fear that if they do, they’ll be retaliated against?

This problem can be further exacerbated in organizations where employees do not trust the company. They will tell the company what it wants to hear on surveys rather than be honest. This means that employee survey results are skewed because employees do not trust the confidentiality of the survey and are telling the company only what they want and expect to hear. That makes it even more challenging to understand what may be going on in the organization.

Now let’s look at multinational/multicultural organizations and whether there are differences to consider when assessing a global company. There can vast culture differences which come into account around hotlines, reporting and even disrespect of a supervisor. This means one must “fine-tune” a cultural survey to get a good understanding of the company’s culture and obtain meaningful metrics. In these situations, there are other metrics you can look at; consider the data and cases of employees coming forward and saying, “something just doesn’t look right” without being anonymous. Using surveys and even focus groups can be helpful to gauge this type of comfort level, most particularly if an external independent third party is involved.

The bottom line is that it is helpful to take the temperature of your employees internally by doing regular monitoring to understand the company’s culture and what needs to be done. However, employees are not going to be as honest and forthcoming with someone inside the company as they would be with an independent third party. This is because employees are almost always afraid of the potential blowback from superiors.

Employees will be much more reserved with people they know or people in their own company, so it can be more powerful and more effective for an independent third party to perform cultural assessment work.

Please join me next week for my concluding post in this series on how ethical culture is a part of an overall ethics and compliance assessment.


In case you missed the earlier installments of this ongoing series, please see the links below.

Everything You Always Wanted to Know About Monitors But Were Afraid to Ask

Part 1, Part 2, Part 3, Part 4 and Part 5

Potential Issues in Corporate Monitorships

Part 1, Part 2, Part 3, Part 4 and Part 5

Suspension and Debarment in Monitoring

Part 1, Part 2, Part 3, Part 4 and Part 5

Monitoring in the Health Care Sector

Part 1, Part 2, Part 3, Part 4 and Part 5

The Basics of Corporate Culture

Part 1, Part 2, Part 3


Tags: Corporate CultureCulture of Ethics
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Jay Rosen

Jay Rosen

Jay Rosen is Vice President, Business Development and Monitoring Specialist at Affiliated Monitors, Inc., the first company in the U.S. to focus on providing independent integrity monitoring and assessment services across a wide range of regulated industries and professions. Jay previously headed up Merrill Brink’s FCPA Investigations and Ethics and Compliance translation group. He has over eight years of experience assisting clients on cross-border investigations, as well as helping them localize their code of conduct and other mission-critical English documents for their global colleagues. For almost three years, Jay has co-hosted the #1 weekly FCPA podcast, “This Week in FCPA,” with Tom Fox. Tom and Jay recently launched a second podcast, “Popcorn and Compliance,” and Jay is also a commentator on the biweekly podcast, “Everything Compliance,” with Jonathan Armstrong, Tom Fox, Sarah Hadden, Matt Kelly and Mike Volkov.

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