Editor: Please tell our readers about Monsanto's Office of Business Conduct.
Echols: Monsanto's board senior management has charged my office to do two things. One is what I would call a typical corporate compliance program. The second is to focus this program on values-based business conduct. Our values reflect our commitment to doing the right thing, tackling tough issues with integrity.
A compliance-based program highlights the rudimentary elements of the law. Its training aspects help employees to understand the letter of the law. Integrity, however, means more than observing the letter of the law. It means doing the right thing, even in situations that are not governed by any specific law or where the law is not clear.
Editor: How does technology help Monsanto to communicate its commitment to value-based business conduct?
Echols: With more than 13,000 employees worldwide, communication challenges have been enormous. Working with Integrity Interactive is one example of what we are doing to communicate that integrity is the cornerstone of the way Monsanto does business. We began with an off-the-shelf tutorial on a generic code of conduct developed by Integrity Interactive. With the help of a team of internal experts at Monsanto and the educational and the information technology specialists at Integrity Interactive, we adapted the tutorial to (1) give each Monsanto employee a sense of the importance of value-based business conduct; (2) reintroduce our code of business conduct as the basis not only for compliance decisions, but also values-based decisions; (3) remind employees of their obligations to get involved and participate in values-based business conduct; and (4) encourage employees to use the opportunities and mechanisms for communicating with us in the Business Conduct Office. With the help of Integrity Interactive, we are now in the process of sending our adapted tutorial out worldwide.
Editor: Has Integrity Interactive helped you with delivery of your tutorial?
Echols: We delivered the tutorial first in English to all employees at North America and in English-speaking countries worldwide. Integrity Interactive helped with the translation of the off-the-shelf portions of the tutorial, and we translated the portions we developed ourselves. Our tutorial is now translated into 19 languages.
Editor: How do you deliver the tutorial?
Echols: Using a server maintained by Integrity Interactive, we send an e-mail message to our employees, which gives information about how to log onto the tutorial. They can take the courses when they have time to do so. If not timely completed, Integrity Interactive sends reminder e-mails. The initial and follow-up e-mails are sent on behalf of Monsanto executives, so it appears that they are coming from them and not Integrity Interactive.
With Integrity Interactive's help, we developed a facilitator's guide. We use it for training the few employees who do not yet have e-mail addresses. This is not a large percentage, but includes some of our sales force in the Asian Pacific countries, for example.
Editor: How are employees reacting to the tutorial?
Echols: An enormous hit, our tutorial has been so successful that we have had requests in several countries that we give it to our contract employees around the globe. We plan to modify the tutorial further so that we can meet these requests.
Editor: What are some of the characteristics of the Integrity Interactive tutorial that help make it attractive to employees?
Echols: The more interactive, the more effective a tutorial is. Simply delivering text on a screen makes it difficult to concentrate. Text must be segmented with sound, photographs or, if possible, videos. Adults do not want to be passive. What I like about Integrity Interactive's program is that the trainees have to participate.
Integrity Interactive uses a story-based style. Mixed with the text, photographs of actors playing out a role are accompanied by an audio track. The interactive nature of the tutorial helps each trainee get to completion. They cannot skip ahead; they have to answer questions correctly before proceeding to the next step.
Editor: What is the cornerstone of an effective values-based compliance program?
Echols: There are several, but to me it boils down to one thing - management involvement. In every compliance program that I've seen - including Enron's code of conduct, by the way - management has talked the talk. That's fine, but if employees see that the company's first-line supervisors all the way through the CEO are not walking the walk, any compliance program will be an absolute abject failure.
When high-level management is engaged in illegal activity or unethical behavior, you can imagine its effect on a compliance program. Employees simply say, "These people aren't living up to this, why should I?"
Editor: How can management demonstrate its commitment to values-based business conduct?
Echols: Management needs to deliver the message itself. In North America, I sent out the initial e-mail telling employees about our tutorial, and my name is on the reminder messages to employees who do not complete the tutorial on time. Outside North America, our management sends the messages for cultural reasons.
Adding to the training mix, I ask our CEO, Hugh Grant, and the rest of his executive team to set aside time periodically at their staff meetings and town halls to talk about business conduct and our values. We also loaded Monsanto's code of conduct onto our intranet site. The site includes 30 or so scenarios originally developed by one of our employees in Iowa. I realized that, with very little modification, they could be used worldwide to discuss values-based business conduct. I've asked our company's business leaders to use one or two a month to lead a discussion about values-based business conduct with their staffs.
Editor: What areas are covered in your tutorial?
Echols: Monsanto's pledge to integrity can be downloaded from our external web site at www.monsanto.com. Within our pledge are Monsanto's values - honesty, decency, consistency and courage.
Implementing its values, Monsanto's code of conduct focuses on six areas and makes commitments in each area, which are the topics that most companies cover. To be manageable, the code cannot cover every area in detail. This is why values-based guidance is so important. When dilemmas have no clear answer or the situation is not covered in the code, employees need to know where they go for help.
Editor: What resources can help corporate counsel keep up-to-date on laws, regulations and best practices related to business conduct?
Echols: The Ethics Officer Association makes resources available to managers of ethics, compliance and business conduct programs. It offers conferences, education programs, job listings and networking events.
The Association of Corporate Counsel is very good in providing benchmarking tools and updates on the law. Its web casts on Sarbanes-Oxley have been particularly helpful.
Editor: Where can our readers find more information about Integrity Interactive?
Echols: They can visit www.integrity-interactive.com.