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Corporate Compliance Insights
Home Ethics

Why You Need to Operationalize Your Business Ethics

by Jim Nortz
September 24, 2015
in Ethics
Why You Need to Operationalize Your Business Ethics

This article appeared previously Association of Corporate Counsel’s ACC Docket and is published here with permission from the journal.

Several years ago, Mark Dickinson received a call no grandfather should ever have to endure. His two-year-old grandson had suffered a serious head injury and was going to be taken off of life support in a matter of hours in Denver, CO. Mark, who lived in southern California, hurriedly booked a Southwest Airlines flight to Denver and headed to the airport in hopes of seeing his grandson one last time and providing support to his daughter during her hour of need.

When Mark arrived at the airport, his heart sank as he stepped into a very long security line. As he shuffled forward, he called his wife to tell her that it didn’t look like he was going to make the flight. His wife then called Southwest, explained the situation and asked if there was any way they could hold the plane until her husband arrived. The Southwest representative politely stated that she did not have the authority to delay the flight and that many other customers were counting on an on-time departure. After hearing this news, Mark decided to continue to try to make the flight on the slim hope that he would get to the gate in time.

In the meantime, an extraordinary chain of events began to unfold at Southwest. Before taking the next call, the Southwest representative who spoke to Mark’s wife placed a call to the company’s gate representatives at the airport and let them know about the situation. The gate representatives relayed what they had learned to the pilot who was just preparing to close the cabin door and pull away from the gate. He thought about it for a moment and got on the intercom with the passengers. He told them about Mark and asked the passengers to take a vote as to whether to delay the flight. The passengers unanimously voted to wait.

Twenty minutes later, Mark came running toward the gate in his sock feet, so rushed that he just grabbed his shoes at security and ran through the terminal. The pilot greeted Mark in the jetway and said, “Welcome aboard.”

Tragically, Mark’s grandson died. But because of the compassion displayed by Southwest that day, Mark made it to Colorado in time to say goodbye to his grandson and to be there for his daughter.

The remarkable way Southwest responded in the circumstances did not stop there. Most airlines would punish a pilot who holds up a flight. Southwest did the opposite. It applauded the pilot’s actions and held what he did up as a great example of the level of service they aim to provide their customers.

I first learned of this rare act of corporate compassion from Ann Rhoades at an event at Nazareth College in Pittsford, NY. During her talk, Rhoades explained that Southwest’s response to Mark’s plight was not accidental. Instead, it was the direct result of a deliberate decision made early in the company’s history about the kind of culture they wanted to have.

If you go to Southwest’s website, you’ll find their mission statement:

The Mission of Southwest Airlines

The mission of Southwest Airlines is dedication to the highest quality of Customer Service delivered with a sense of warmth, friendliness, individual pride, and Company Spirit.

To Our Employees

We are committed to provide our Employees a stable work environment with equal opportunity for learning and personal growth. Creativity and innovation are encouraged for improving the effectiveness of Southwest Airlines. Above all, Employees will be provided the same concern, respect, and caring attitude within the organization that they are expected to share externally with every Southwest Customer. January 1988

Although this mission statement is fairly well done, it is not unlike similar pronouncements by many other companies who do not enjoy a reputation for living up to their espoused ideals. It is easy to write down and publish laudable corporate aspirations, but it is another thing to operationalize them. To her credit, Rhoades has succeeded in helping Southwest and other companies make this happen.

She details many of her techniques for performing this work in her book entitled “Built on Values – Creating an Enviable Culture that Outperforms the Competition.” The gist of Rhoades’ approach is to carefully select a set of values with specific objectives in mind and then to do the work necessary to imbed them into every aspect of the operation. These ideas are well summarized in her “Organizational Values Assessment Tool,” provided in her book’s appendix, in which she recommends that leaders establish a baseline for their organization by answering the following questions:

  • Does your organization have a set of identified core values?
  • Do those core values drive the decisions made by the organization at all levels?
  • Can every employee within the organization state the values from memory?
  • Has the organization assigned specific behaviors to the values?
  • Are the values integrated into the hiring process? (Do your interview questions reflect the values you are looking for in your candidates?)
  • Are the values integrated into the review process? (Do you hold your employees accountable for living the values by making them a part of their performance evaluations?)
  • Does your organization hire for values? (Are you willing to hire someone who may not have all the trainable skills necessary but does exhibit all of the values?)
  • Does your organization fire for values? (Is your organization willing to fire a high-performing employee who does not live by the values created?)
  • Does your organization provide rewards and recognition to employees based on values?

By candidly answering these questions, you can obtain a clear sense of where your organization falls on the spectrum of companies who really live their espoused values and those who merely publish a collection of nice-sounding corporate slogans. But, answering questions like these is only the start. To truly operationalize an ethical culture in your organization, you and your top leadership have to do something that is very rare: Make a deep commitment and devote the resources necessary to get it done. This takes a genuine passion for the work, thoughtfulness and careful planning to ensure all the pieces fit into a coherent whole.

Figuring out how to operationalize your organization’s ethical standards is much easier said than done. It is only by emulating companies like Southwest, who take this work seriously, that your organization can strive to establish what Rhoades refers to as a “self-reinforcing circle of excellence” that will maximize your chances for success.


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Jim Nortz

Jim NortzJim Nortz is Founder & President of Axiom Compliance & Ethics Solutions LLC, a firm dedicated to driving ethical excellence by helping organizations implement effective compliance and ethics programs. Jim is a nationally recognized expert and thought leader in the field of business ethics and compliance with over a decade of experience serving multinational petrochemical, staffing, business process outsourcing, pharmaceutical and medical device corporations. Jim spent the first 17 years of his career as a criminal and civil litigator and Senior Corporate Counsel before becoming Crompton Corporation’s first Vice President, Business Ethics and Compliance in 2003. Since then, Jim has served as a compliance officer at Crompton and for five other multinational corporations, the most recent of which was as Chief Compliance Officer at Carestream Health. Jim has extensive experience in implementing world-class compliance and ethics programs sufficiently robust to withstand U.S. Department of Justice scrutiny. Jim is a frequent guest lecturer at the University of Rochester’s Simon School of Business, RIT’s Saunders School of Business, St. John Fisher College, Nazareth College and other law schools, universities and organizations around the country. Jim writes the monthly business ethics columns for the Association of Corporate Counsel Docket magazine and the Rochester Business Journal. Jim is a National Association of Corporate Directors Fellow, a member of the International Association of Independent Corporate Monitors and serves on the Board of Directors of the Rochester Chapter of Conscious Capitalism as the Board’s Secretary and Chair of the Governance and Nomination Committee. Previously, Jim served on the Board of Directors for the Ethics and Compliance Officers Association and the Board of the Rochester Area Business Ethics Foundation.

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