Corporate Ethics Programs and Security

Rose Shyman added an ethics program to her duties as director of global security at American Standard Cos.

By Todd Datz

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How did ownership of the program fall to the CSO?

Our general counsel felt that our values program should not be owned by the legal department. We are striving to create an ethics culture at American Standard, one he felt the businesses should drive. As a result, the general counsel and Fred Poses appointed one of our business leaders to chair the ethics and integrity council [Craig Kissel, president of the Vehicle Controls division, Wabco], and also insisted that the security function administer the program. We felt that this was the right thing to do for our people.

What are some of the reasons it works well to have it under security?

We believe that the roles [of security and ethics] are naturally aligned. Corporate security has an inherent compliance component. Compliance is one facet of our ethics program. Security also focuses on modeling desired behaviors through awareness programs. The same is true of our ethics program's goals.

What are some of the ways of operationalizing the program?

We have approximately 65 "ethics advisers" who are represented functionally and geographically across the businesses [see "5 Steps to an Ethical Culture," this page]. These are essentially go-to folks in the field who provide guidance to employees dealing with ethical situations. We have quarterly conference calls, educational sessions where we provide the advisers with [ongoing training]. We invite subject-matter experts to attend the calls to provide education on various different topics. For example, we [recently] invited our VP/comptroller for American Standard to talk to the group about financial integrity, which is highlighted in our Code of Conduct and Ethics [see "Code Read," Page 62]. We offer online ethics training as well. [The ethics advisers are] the group that helps provide guidance in all we do.

When employees call your values hotline with an ethics concern, what's the process?

[Editor's note: American Standard uses The Network as its third-party provider of hotline reporting services. The Network's Ralph Childs responded to readers' questions about compliance and ethics in the May Security Counsel column.]

An operator takes the call and asks a set of questions. You know, who they are, their title, what [line of] business they're from and so forth. In some cases [callers] want to remain anonymous, and that's fine. They present the facts of the case. We capture as much as we can within a case file. Then the case file is sent to me.

[Editor's note: Each case is given a code that allows anonymous complainants to follow up with the hotline.]