Every now and then, part of organization’s personnel is required to declare or update conflicts of interest. Compliance Officers are then left to the task of assessing these declarations. However, it is fairly plausible to assume that what ends up on Compliance Managers’ desks will not be the full picture of factually existing conflict of interests.
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This article emphasizes on how to obtain a more complete picture of an organization’s conflict of interest landscape and on how to better prevent non-compliance in general – with a strategic tweak in the way to communicate with employees.
One of the unchallenged observations in the field of behavioral compliance is that people cheat less than they could but more than they should. Nevertheless, the detailed rationale behind this observation is more disputed. What seems to be one of the main drivers of human alignment to rules in an organizational context is the self-perception of “doing the right thing”. In other words, we like to have a positive self-image. This does not change just because we knowingly cheat. The process of restoring our positive self-image when breaking the rules is known as rationalization or neutralization. Neutralization is nothing more than finding good reasons for why to cheat (or having cheated). These neutralizing processes continue until the positive self-image is restored.
Researchers* have found that an effective method to deter employees from non-compliance behavior is to target the neutralization process itself: anti-neutralization communication. Certainly, it is necessary to inform employees about the rules as well as their importance and what the consequences of non-compliance are. But what seems to be particularly effective is targeting the possible reasons an employee might come up with to justify the non-compliant behavior. Timing is crucial: the effect of anti-neutralization communication is expected to be stronger right before a potential non-compliant behavior.
What does this mean in the case of conflict of interest declarations?
First, whenever reminders are sent out to employees urging them to declare their conflicts of interest, anti-neutralization statements such as the following should be included:
Being truthful means declaring all conflict of interests (counters neutralization strategy “Leaving out information is not lying”).
It does not matter how important the conflict of interest is perceived to be (counters neutralization strategy “I have already declared the most important ones, so I can skip the rest”).
If you become aware of undeclared conflict of interests of your colleagues, talk to your line-manager or inform the Compliance Office (counters neutralization strategy “The others do not declare everything either”).
Second, if there is an (electronic) form employees are requested to fill in, anti-neutralization statements should be included at the top of the form. This ensures that anti-neutralization statements are present right before the potential non-compliant behavior might occur.
Conflict of interest declarations are just one example of how anti-neutralization communication can improve compliance. If institutionalized, for example with regular anti-neutralization training of employees, a broader and long-lasting effect can be achieved.
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*Research used for this article:
Bersoff, David M. (2001): Why good people do bad things. Motivated reasoning and unethical behavior
Heath, Joseph (2008): Business ethics and moral motivation: A criminological perspective
Barlow, Jordan B. et al (2018): Don't Even Think About It! The Effects of Antineutralization, Informational, and Normative Communication on Information Security Compliance