Over this series I am visiting with Peter Johns, Chief Marketing Officer, and Rebecca Turco, Vice President of Learning, both at SAI Global, the sponsor of this podcast series. In the series we are discussing the changes in ethics and compliance (E&C) learning and how a more technology-based learning solution can help move your company to a more effective and more operationalized best practices compliance program. In Part III, I speak with Rebecca Turco on the new SAI Global training solution at EthicsAnywhere.
EthicsAnywhere is SAI Global’s new training E&C solution. The solution began with an internal conversation at SAI Global and then moved to an extended conversation with their customer base. The idea that somewhere a new hire is spending their first day sitting through two hours of mandatory compliance training and one of their colleagues needs to complete a time sensitive course but they are traveling to meetings all week, and their manager is trying to figure out who has or has not finished their training yet, and a Chief Compliance Officer (CEO) is in the midst of planning their next launch of content without fully understanding how effective their previous efforts have been. How can you provide a training solution to meet these needs but meets the Department of Justice (DOJ) requirements that it be both effective and targeted?
For the new employee going through the compliance training, there is no context around it. You have managers who say, I need you to do the training and I need you to complete it because I am measured on that for my compensation. Yet in such a situation you might not be starting the training off on the right foot. One of the ideas behind EthicsAnywhere is that we live in a world where content is consumed and people make decisions if they agree with a piece of content or disagree within seven seconds of starting. If they are not engaged by that time, they will usually not pay attention anymore. EthicsAnywhere is designed to be engaging, literally grabbing the attention of the employee right out of the box.
Turco emphasized that we all know that millennials and centennials spend a lot of time on their phones, but the reality is that according to the Pew Research Center, every demographic of people in your company today spend more time online on their phones than their computers. So, when regulators ask if your training is in the ‘form appropriate for the intended audience’, we’d argue that a computer is no longer the appropriate form for the intended audience, and not offering training on mobile devices in the appropriate languages could actually pose a problem from an employee and regulatory perspective.”
This insight into the use of technology by millennials and centennials informed how the EthicsAnywhere compliance training solution should not only work but how its delivered. That delivery is as easy as opening up an application on their cell phone. This technological innovation removes barriers to compliance training and more fully engages the audience. Compliance programs have shifted to use better technology to make it easier for people to access content information which improves not only the effectiveness of the training but also the experience.
But there is a second innovative part to the EthicsAnywhere and that is the content. It is designed to “make sure that we have content that we can serve up to learners anywhere, literally anytime, whether they’re out on the road, in a sales meeting where they are accessing from it from their phone, if whether they are sitting in their workspace on their computer.”
The idea for EthicsAnywhere is to “provide meaningful solutions to our clients and our partners. This means relevant, meaningful content using all the delivery mechanisms of technology that exists today. The next step is to make this ethics and compliance learning program tailored and relevant for not only each company but also for each learner. For the learner, this means making sure that we are meeting them where they are and giving them what they need. It is being able to review your ethics and compliance training wherever you are and make it as simple as possible for you to get into an access information.” Turco explained that millennials and centennials want to receive their training on their cell phones and they want it to look like any other piece of content that are looking at today. In short there should not be any entry barriers to receive the training.
One final thing about millennials which is extraordinarily positive, is that they seem to be very values driven and they are very focused on culture to drive the value base. They are very focused on a what companies do and what the reputation is in the workplace and in the marketplace. If a company has a misstep or makes a mistake, they expect a remedy. All of this tied into Turco’ final point about EthicsAnywhere, which is that it “is a modern approach to learning. It is responsive on any device, customizable for any organization, targeted to any user, available in any location, and translated in any language, so your employees can consume content at any time and prepare for any risk, and you can collect data to measure any goal your ethics and compliance program may have.”
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Over this series I have been visiting with Peter Johns, Chief Marketing Officer, and Rebecca Turco, Vice President of Learning, both at SAI Global, the sponsor of this podcast series. We are discussing the changes in ethics and compliance learning (E&C) and how a more technology-based learning solution can help move your company to a more effective and more operationalized best practices compliance program. In Part IV, I visit with Rebecca Turco on the current trends she is seeing in culture, ethics and compliance (E&C) and where it all may be headed.
We began the discussion with adaptive learning, which is more of a personalization way to learn. It is key for the compliance ethics discipline because adaptive learning “really looks at how do we differentiate the content for the learners? How do we start to serve up content that’s relevant based on role or region? How do we help learners?” Adaptive learning is designed to focus on “making sure the learners are getting the content and relevant information that they need within any piece of content. It begins with asking questions about where they work and whether they interact with government officials. From there, it moves to serve up content to the employee which is meaningful, that helps them start to see what risks are in their area. It also allows content designers to be able to give them a personalization to the training experience that is more meaningful than just kind of a one size fits all.”
Another key usefulness of this approach is that it does not reinvent training for employees who do not need it. This comes from “giving people credit for understanding risks, giving them the ability to kind of test out, by asking them a series of questions and if they know the answers, they may know what their risks are and they can move to a level at which they do not know the answers. You do not need to train employees in areas where they have demonstrated competency. This gives companies the opportunities to really think about their program and differentiate the ethics and compliance training of their compliance program.” Turco concluded, “in the world today, people are looking for compliance training that is as short and sweet as possible, getting to the relevant pieces of information.”
Another innovation in E&C learning has been around the concept of branching. Turco explained this is building out different scenarios. She provided an example of training about “a security breach. Things happen on a video and the learner is watching them unfold. By using adaptive technology you can require the learner to pick out the hotspot where they would see a risk or something being violated. From there the video would branch off into different scenarios based on what you decide because that’s real life. It is not the first decision that causes an ethical breach or a security breach. It’s for decisions down the road. That’s the hard part in training to get right because it is not always just as black and white as is the conflict of interest might lie.”
We next turned to the area of the effectiveness of compliance training, which, Turco said, “is the key story for compliance”. Interestingly, Turco said the first question asked is about the content of the training, not the data around this issue. She explained, “you can collect as much data as you want for any, any reason but if the content you are writing and designing for the training is not meaningful, then the data you’re getting isn’t meaningful.” (as fine a definition of GIGO as I have ever heard.) She said that a company must really think about data and how to use it to make your program smarter and to make you understand where the risks are in your organization.
Effectiveness then starts with building content with thought provoking questions in the presentation. This leads to scenarios which ask the learner, “what do you think?” From there you can begin collecting the data from their responses and start to analyze it on the back end. This can give you trends about whether there is a disconnect in your written Code of Conduct, policies and procedures and how business is operationalized in the field. With this data, an organization can start to target campaigns to that team around that risk area identified. Turco pointed to one example where a company was able to demonstrate through this approach a training competency and effectiveness increase from 20% to 80% in one year.
Your goal should be that the needle is moving and your organization is providing employees the tools in order to make sure they have the knowledge and the competency to not only pass that assessment but also understand those risks in the business. This is far beyond the “check the box” method of training. With the speed of current day corporate decision making in the field and the pressure your sales teams are under to meet goals, timelines and deadlines; you need to provide training to meet these business realities. Once you understand that, then you can start to understand how to provide your employees effective training.
Turco concluded by noting that your training should aid in the decision-making process when the teams are under pressure; whether that be sales pressure, pressure due to a high-risk region or other. Turco said, “How do you make sure that when they’re under that pressure, they will know exactly what to do?” The data collected from the training process can help identify risks, provide the opportunity to help employees understand more and drive training or campaigning around risks.
Over this podcast series I have been visiting with Paul Johns, Chief Marketing Officer, and Rebecca Turco, Vice President of Learning, both at SAI Global, the sponsor of this podcast series. We have been discussing the changes in ethics and compliance (E&C) learning and how a more technology-based learning solution can help move your company to a more effective and more operationalized best practices compliance program. In this final episode, I visit with Paul Johns on the need for an integrated approach to risk management.
One of the primary reasons why an integrated approach to risk management is mandatory in today’s business environment is the increasing amount and complexity of risk which every company and, indeed, every Chief Compliance Officer (CCO) face. Moreover, social media has amplified every action and reaction both in terms of signal strength and speed of dissemination and communication. New risks include the parties you are working with down the line to 3rd, 4thand 5thlevel suppliers and sales representatives. Obviously cyber risks are greatly increased as well. From consumers or customers, however, the calculation is strikingly simple - did your company do the right thing?
It is only through an integrated risk management strategy that you can being to prepare your company to do business in the modern world. Such a strategy includes (1) forecasting, (2) risk assessment, (3) risk-based monitoring and (4) feedback of information gleaned from your monitoring into your risk strategy going forward. Yet it is more than the risk management process; it is using each part of your compliance program to develop information which can make your overall risk management strategy more robust.
While this five-part series has focused largely on compliance and ethics training, consider how an integrated approach to risk management works even with training. As Turco noted regarding adaptive learning, it is designed to focus on “making sure the learners are getting the content and relevant information that they need within any piece of content. It begins with asking questions about where they work and whether they interact with government officials. From there, it moves to serve up content to the employee which is meaningful, that helps them start to see what risks are in their area.” By asking questions to deliver an appropriate training solution, you begin to develop information about the state of your compliance program. If you are weak in some areas, you may wish to engage in remediation. If you strong in other areas, you can use those employees as Compliance Ambassadors within your organization to be a redource to other employees.
Johns tied this concept to your overall risk management strategy by noting it is only as strong as the weakest link. In the area of compliance training, this means if you have a high employee turnover, as is common in retail companies, your annual Code of Conduct training may not be sufficient to catch all employees every year. Moreover, if such training is run out of Human Resources (HR), the compliance function and hence senior management and the Board of Directors may not even be aware of this gap. But you may not even be aware of this gap unless you ask questions or consider what the data is telling you.
Some other questions Johns posed in the context of an integrated risk management strategy are if your company moves to a new geographic region or opens a new sales line, have all of your policies and procedures been updated to reflect this change in your risk profile? Has anyone considered such a move from the risk perspective? Are you even assessing such risks before product implementation or change in sales strategy? From the Board and Chief Executive Officer (CEO) perspective, have they been presented with an integrated risk report from which they can even begin to assess the risk in front of them? Your sales model will directly impact your risk under anti-corruption laws such as the Foreign Corrupt Practices Act (FCPA). Third-party risks are still the highest risks under the FCPA. However, an employee-based sales strategy also presents risks, albeit a different set of risks. (Consider GSK in China.)
Another interesting reflection from Johns was that with the more flexible nature of a workforce, including those on flex time, working from home, working during a commute and those who are essentially on 24-hour call; these innovations in working conditions demand an innovation in ways that training and ongoing communications are delivered. This means a company should have a mobile platform for learning and communication that can deliver its messages to employees when and how they want (and need) to consume it. This also ties into questions about not only content but the technology you use to deliver that content. When was the last time you considered the technology you are using in terms of the best manner to deliver the appropriate content?
Johns concluded with quite an interesting observation on the role of compliance and risk management. It is to become the new Praetorian Guards, which is to say put a ring around the senior executives to protect them. (Note - I am a fan of the Alamo analogy articulated by Chuck Duross but then again, all the defenders at the Alamo died.) He also alluded to the offensive nature of the Praetorian Guard. This also ties more closely into how a more fully operationalized compliance program makes a business run more efficiently and at the end of the day, more profitably.
In this episode, I visit with podcast favorite Matt Ellis, a member at Miller & Chevalier on the firm’s always excellent FCPA Summer Review 2018. The first half of 2018 has brought some very interesting FCPA enforcement actions, packed with lots of information for the compliance practitioner. We unpack the key enforcement actions, international developments and some key statistics. Some of the discussion highlights include:
To download a copy of Miller & Chevalier’s FCPA Summer Review 2018, click here.
As Hurricane Florence has made landfall onto the Carolinas and beyond, Hurricane Issac is hurtling towards the Gulf of Mexico and Storm X is taking aim at Texas, Tom and Jay are back with a look at some of the week’s top compliance and ethics stories.
For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.
Welcome to the only roundtable podcast in compliance. Inspired by our UK colleague, Jonathan Armstrong who inquired if we could explore the guilty plea of Michael Cohen and the guilty verdict against Paul Manafort, we dedicate the next two episodes to issues surrounding, raised by or related to these two events. In this episode we have commentary by Jay Rosen and Jonathan Armstrong (last week was Mike Volkov and Matt Kelly). After the commentary we follow with rants.
The members of the Everything Compliance panelist are:
The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist.
In this episode of the CONGERGE18 Preview Podcasts series, I visit with Keturah Pestel, Program Manager, Business Ethic and Legal Support Office at Thrivent. We discuss her company’s innovative use of internal reporting. Some of the issues we tackle in this podcast are:
In what is fast becoming one of the top ethics and compliance conferences around, I hope you can join me at CONVERGE18, hosted by Convercent. (I perform consulting work for Convercent.) This year’s event will be October 8-11 at the Omni in Bloomfield, Colorado. The line-up of this year’s event is simply first rate with some of the top ethics and compliance practitioners around.
I hope you can join me at the event. For information on the event, click here. As an extra benefit to readers of this blog, CONVERGE18 is offering a 50% discount off the registration price. Enter discount code TOMFOXVIP.
CONVERGE18 is a production of Convercent, which is the sponsor of this podcast series.
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I take a very deep dive into the recent SEC whistleblower award of $54MM to two separate individuals.
Some of the highlights from this podcast are:
We unpack of all these points and consider strategies going forward.
For more reading: see Matt’s piece $54M SEC Whistleblower Award
In this episode of the CONGERGE18 Preview Podcasts series, I visit with Sheryl Zaworski, VP, Director of Global Ethics Escalation, Investigation and Analytics at U.S. Bank. We discuss the the data project at US Bank. Some of the issues we tackle in this podcast are:
In what is fast becoming one of the top ethics and compliance conferences around, I hope you can join me at CONVERGE18, hosted by Convercent. This year’s event will be October 8-11 at the Omni in Bloomfield, Colorado. The line-up of this year’s event is simply first rate with some of the top ethics and compliance practitioners around.
I hope you can join me at the event. For information on the event, click here. As an extra benefit to readers of this blog, CONVERGE18 is offering a 50% discount off the registration price. Enter discount code TOMFOXVIP.
CONVERGE18 is a production of Convercent, which is the sponsor of this podcast series.
Over this series, I have visited with Eric Feldman, Senior Vice President, Don Stern, Managing Director of Corporate Monitoring & Consulting Services, and Rod Grandon, Managing Director of Government Services, from Affiliated Monitors, Inc., (AMI) who is the sponsor of this series. In it, we explore how to go about assessing ethics and compliance in the mergers and acquisition (M&A) context. In this fifth and concluding episode I visit with Stern to tie together how an independent integrity monitor can benefit the entire M&A process.
In this episode we discuss:
I have been visiting with Eric Feldman, Senior Vice President, Don Stern, Managing Director of Corporate Monitoring & Consulting Services, and Rod Grandon, Managing Director of Government Services, from Affiliated Monitors, Inc., (AMI) who is the sponsor of this series. In it, we explore how to go about assessing ethics and compliance in the mergers and acquisition (M&A) context. In this fourth episode I visit with Grandon about the types of things a monitor would review to determine if a company adequately considered ethics and compliance during the M&A process.
In this episode we discuss:
Over this special five-part podcast series, I will visit with Eric Feldman, Senior Vice President, Don Stern, Corporate and Rod Grandon, Managing Director Government Services; all from Affiliated Monitors, Inc., who is the sponsor of this series. In it, we explore how to go about assessing ethics and compliance in the mergers and acquisition context. In this third episode I visit with Feldman planning out your post-acquisition merger strategy.
In this episode we discuss:
Over this series, I am visiting with Eric Feldman, Senior Vice President, Don Stern, Managing Director of Corporate Monitoring & Consulting Services, and Rod Grandon, Managing Director of Government Services, from Affiliated Monitors, Inc., (AMI) who is the sponsor of this series. In it, we explore how to go about assessing ethics and compliance in the mergers and acquisition (M&A) context. In this second episode I visit with Stern on the impact that M&A has on both the acquired entity and the acquirer.
Some of the highlights include:
Over this series, I am visiting with Eric Feldman, Senior Vice President, Don Stern, Managing Director of Corporate Monitoring & Consulting Services, and Rod Grandon, Managing Director of Government Services, from Affiliated Monitors, Inc., (AMI) who is the sponsor of this series. In it, we explore how to go about assessing ethics and compliance in the mergers and acquisition (M&A) context. In this first episode I visit with Feldman on the why’s, what’s and how’s of an independent assessment of a target.
In this episode some of the key discussion points are:
In this episode, I visit with podcast fan favorite Laura Perkins, a partner at Hughes, Hubbard and Reed. We discuss the recent 2ndCircuit Court of Appeals decision in the Hoskins matter. With Laura’s background as a former Justice Department prosecutor in the FCPA Unit, she brings a wealth of knowledge to what the decision may portend for the prosecution of FCPA cases going forward and how may impact corporate compliance programs as well. Some of the discussion highlights include:
For a copy of the Hoskins opinion, click here.
As the Houston Texans head to Boston for the NFL Season Opener and the Houston Astros head to Boston for a preview of the ALCS , Tom and Jay are back with a look at some of the week’s top compliance and ethics stories.
For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.
Welcome to Everything Compliance, the only roundtable podcast in compliance. Inspired by our UK colleague, Jonathan Armstrong who inquired if we could explore the guilty plea of Michael Cohen and the guilty verdict against Paul Manafort, we dedicate the next two episodes to issues surrounding, raised by or related to these two events. In this episode we have Mike Volkov and Matt Kelly. Next week Jay Rosen and Jonathan Armstrong. After the commentary we follow with rants.
The members of the Everything Compliance panelist are:
The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist.
In this episode of 12 O’Clock High, a podcast on business leadership, Richard Lummis and I continue to explore leadership lessons from GE. Today, we continue our exploration of the travails at GE, focusing on the mergers and acquisition strategy which led to the company’s problems. Some of the issues we consider are:
Sources:
How Jeffrey Immelt’s ‘Success Theater’ Masked the Rot at GE
GE: A Total Leadership Failure
GE’s Fall Has Been Accelerated by Two Problems. Most Other Big Companies Face Them, Too
In this episode of the CONVERGE18 Preview Podcasts series, I visit with David Bunker, Compliance Officer at Vulcan Inc. We discuss managing the risk of conflicts of interest when employing workers in the GIG economy. Some of the issues we tackle in this podcast are:
In what is fast becoming one of the top ethics and compliance conferences around, I hope you can join me at CONVERGE18, hosted by Convercent. (I perform consulting work for Convercent.) This year’s event will be October 8-11 at the Omni in Bloomfield, Colorado. The line-up of this year’s event is simply first rate with some of the top ethics and compliance practitioners around.
With the acceleration of the speak up culture and organizational accountability that social media is enabling and amplifying, companies need to incorporate integrity into every level of the organization. CONVERGE18 will help you do just that by addressing this ethical transformation head-on. Get the insights, information and solutions you need to put ethics into action. Join compliance executives from Salesforce, Kimberly Clark, Avis, U.S. Bank, AARP, Wells Fargo, Cheesecake Factory and many others to:
I hope you can join me at the event. For information on the event, click here. As an extra benefit to readers of this blog, CONVERGE18 is offering a 50% discount off the registration price. Enter discount code TOMFOXVIP.
CONVERGE18 is a production of Convercent, which is the sponsor of this podcast series.
In this episode of the CONVERGE18 Preview Podcasts series, I visit with Eric Feldman, Senior Vice President at Affiliated Monitors. We discuss the issue of perverse incentive and compliance. Some of the issues we tackle in this podcast are:
In what is fast becoming one of the top ethics and compliance conferences around, I hope you can join me at CONVERGE18, hosted by Convercent. (I perform consulting work for Convercent.) This year’s event will be October 8-11 at the Omni in Bloomfield, Colorado. The line-up of this year’s event is simply first rate with some of the top ethics and compliance practitioners around.
With the acceleration of the speak up culture and organizational accountability that social media is enabling and amplifying, companies need to incorporate integrity into every level of the organization. CONVERGE18 will help you do just that by addressing this ethical transformation head-on. Get the insights, information and solutions you need to put ethics into action. Join compliance executives from Salesforce, Kimberly Clark, Avis, U.S. Bank, AARP, Wells Fargo, Cheesecake Factory and many others to:
I hope you can join me at the event. For information on the event, click here. As an extra benefit to readers of this blog, CONVERGE18 is offering a 50% discount off the registration price. Enter discount code TOMFOXVIP.
CONVERGE18 is a production of Convercent, which is the sponsor of this podcast series.
In this episode of the CONVERGE18 Preview Podcasts, I visit with Ellen Hunt, Senior Vice President, Audit, Ethics & Compliance Officer at AARP. We discuss the role of the Board of Directors and compliance. Some of the issues we tackle in this podcast are:
In what is fast becoming one of the top ethics and compliance conferences around, I hope you can join me at CONVERGE18, hosted by Convercent. (I perform consulting work for Convercent.) This year’s event will be October 8-11 at the Omni in Bloomfield, Colorado. The line-up of this year’s event is simply first rate with some of the top ethics and compliance practitioners around.
With the acceleration of the speak up culture and organizational accountability that social media is enabling and amplifying, companies need to incorporate integrity into every level of the organization. CONVERGE18 will help you do just that by addressing this ethical transformation head-on. Get the insights, information and solutions you need to put ethics into action. Join compliance executives from Salesforce, Kimberly Clark, Avis, U.S. Bank, AARP, Wells Fargo, Cheesecake Factory and many others to:
I hope you can join me at the event. For information on the event, click here. As an extra benefit to readers of this blog, CONVERGE18 is offering a 50% discount off the registration price. Enter discount code TOMFOXVIP.
CONVERGE18 is a production of Convercent, which is the sponsor of this podcast series.
In this episode of the CONVERGE18 Preview Podcasts series, I visit with Philip Winterburn, Chief Product Officer at Convercent. We discuss the issue of perverse incentive and compliance. Some of the issues we tackle in this podcast are:
In what is fast becoming one of the top ethics and compliance conferences around, I hope you can join me at CONVERGE18, hosted by Convercent. (I perform consulting work for Convercent.) This year’s event will be October 8-11 at the Omni in Bloomfield, Colorado. The line-up of this year’s event is simply first rate with some of the top ethics and compliance practitioners around.
With the acceleration of the speak up culture and organizational accountability that social media is enabling and amplifying, companies need to incorporate integrity into every level of the organization. CONVERGE18 will help you do just that by addressing this ethical transformation head-on. Get the insights, information and solutions you need to put ethics into action. Join compliance executives from Salesforce, Kimberly Clark, Avis, U.S. Bank, AARP, Wells Fargo, Cheesecake Factory and many others to:
I hope you can join me at the event. For information on the event, click here. As an extra benefit to readers of this blog, CONVERGE18 is offering a 50% discount off the registration price. Enter discount code TOMFOXVIP.
CONVERGE18 is a production of Convercent, which is the sponsor of this podcast series.
You can put away your all white linen suits and your seer sucker suits as well. With that hint of fall in the air, we are upon the (unofficial) end of summer with the Labor Day Weekend, Tom and Jay are back with a look at some of the week’s top compliance and ethics stories.
For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.
The Administration’s attacks on allies, perhaps former allies and other in the area of trade and sanctions has not occurred in vacuum. Many other countries and groups such as the EU have retaliated with counter-sanctions. One area that the current administration does not seem to have considered too well is EU data privacy and data protection. In this episode of Life with GDPR we explore this issue in the age of trade policy as conflict. Some of the highlights are:
For more information on Cordery Compliance, go their website here. Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.
What is due diligence? What is zero tolerance? How do these impact employee morale? How do these concepts link together? Richard Lummis and I explore these questions and more in considering the July Houston Astros trade for closer Roberto Osuna. The primary reason for these questions was that Osuna came off a 75-game suspension by Major League Baseball (MLB) for violation of its domestic abuse policy. It involved an incident for assault, for which Osuna pleaded not guilty to in a criminal case in Ontario. Some of the questions we consider are:
What is Zero Tolerance? Overlaid with Osuna and his suspension were the Astros, who have (or perhaps more appropriately had) a zero-tolerance policy for domestic abuse. David Barron, writing in the Houston Chronicle, said the club’s response was that the zero-tolerance policy did not apply to Osuna because the alleged assault occurred before he joined the Astros and that Osuna would benefit from “great examples of character in our existing clubhouse that we believe will help him and his family establish a fresh start.”
What is the purpose of employment sanctions?Should a person who commits a crime or unethical action be forever banned from practicing their craft? In his article Barron quoted Cindy Southworth, an executive vice president of the National Network to End Domestic Violence, who posed the following question “How do you balance redemption and behavioral change with holding people accountable?” She then answered her own question with “It’s messy. It’s not straightforward. But you can do both.” I would only add (parenthetically) that if your right arm is a cannon, you will probably get such a chance.
What are red flags and are they a predicter of future events?One incident of unethical behavior would be seen as a red flag for similar behavior in the future. It might be enough to prevent such a person or entity from passing a due diligence background screening. On the other hand, a person convicted or found guilty of bribery and corruption might well serve their time, become rehabilitated and use those experiences to help others avoid the scourge of corruption going forward.
What is Due Diligence?Is it a formal record check to see if a person is on the despicable persons list, have committed criminal acts or are at least alleged to have violated laws. Is due diligence determining whether someone or some other organization meets the minimum standards you set for yourself or your organization (See: zero tolerance, above)? Gonzales said, the “Astros say they truly don’t know the details about what took place between Osuna and the alleged victim.”
What is employee morale? Osuna is under charges in the province of Ontario for his domestic assault, to which he has pled not guilty. What will be the effect on all of this be in the Astros clubhouse, given the stances by several players on domestic abuse? Barron noted in his article that Astros pitchers Justin Verlander and Lance McCullers had previously made statements “against players who commit domestic violence.” Verlander said after the trade was announced “Obviously I’ve said some pretty inflammatory things about stuff like this in the past and I stand by my words. But I think in an ongoing case as is this one, we’ll see what happens.” Gonzales reported that Collin McHugh, the team’s representative with the Major League Baseball Players Association, was a bit more direct saying, “I don't think anybody’s comfortable with the situation,” McHugh later told the media. “I don't think anybody in baseball is comfortable with this situation. There’s a lot of ongoing things; there’s things that are happening. Nobody in this clubhouse is going to condone anything that’s happened off the field.”
Moral bankruptcy or shrewd business move?As for the Astros, it is pretty clear that the right arm of Osuna is the only currency the club is concerned about as it mounts a defense of its 2017 World Series championship. Yet in the court of public opinion, the Astros have certainly dropped a few notches. ESPN’s Buster Olney said of the trade, “Surprising…disappointing…shocking….appalling.” Yahoo! Sports’ writer Jeff Passan was even more direct when he said the Astros had engaged in “moral bankruptcy by acquiring a player of tainted character, because, in this case, he can get outs in the ninth inning.”