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Leadership and Ethical Decision Making

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Scenario:

After many years of hard work in lower and then middle management roles, your career further advances with your appointment to the newly created position of compliance officer for Expert Consulting Group (ECG). This position is the first time that you will be a member of a senior executive team, holding what many would consider an organizational leadership role. There are several challenges and opportunities ahead as you become acclimated to the company and fulfill expectations in the new role.

You have been charged with the tasks of standardizing ethical policies at ECG and implementing them company wide, including essential training. You will be the leader consulted by stakeholders regarding matters that could have code of conduct implications. You will oversee the Ethics Review Committee, which is composed of selected executives. The policies developed are intended to provide greater definition to appropriate work-related behaviors and ensure that ECG and its employees are abiding by all legal and ethical guidelines defined by government, other regulatory bodies, and the company. The ethical policies will also define investigative measures if violations are alleged and any punitive actions if violations are confirmed.

This is also an exciting time for the expanding company of ECG. It has grown from being a small, 25-employee boutique consulting firm focused on information technology (IT) solutions for the financial services industry to a consulting firm of 200 employees with four areas of expertise and four industry practices serving clients in the United States and select European and Asian countries. In the past 6 years, ECG's growth has been fueled by carefully planned acquisitions of selected start-ups and strategic recruiting of respected consultants who could quickly add to the annual sales, which currently exceed $60 million. The company's expansion is expected to accelerate through an initial public offering (IPO) of common stock by the end of the quarter to secure additional financing for more significant acquisitions, including that of the privately held firm Government Allies, Inc. Funding secured from the IPO will also allow ECG to strengthen its resources and capabilities.

Currently, ECG promotes itself as being the firm of choice for IT solutions, supply chain management, customer relationship management, and strategic consulting. Industries of focus and expertise include financial services, communications, retail, and transportation. The intended acquisition of Government Allies would enhance IT consulting expertise and allow ECG to secure a foothold in Federal Government contracts, a primary focus for Government Allies. Both companies are excited about the organizational synergies upon the hopeful completion of the transaction.

Similar to many organizations, ECG is required to abide by various laws relevant to domestic and international transactions, such as reporting to governmental agencies, and HR-related laws. During consulting engagements, ECG may or will need to adhere to guidelines for specific client industries. Client contracts also govern work-related activities with rules of engagement. Furthermore, the intended IPO would necessitate rapid and full compliance with the Sarbanes-Oxley Act (SOX).

As the new compliance officer, you must review the existing ethical standards, research relevant laws, seek input as needed, and develop a comprehensive code of conduct for ECG. The much- publicized ethical transgressions of various well-known corporations have heightened organizational and regulatory sensitivities to establishing and abiding by firm ethical standards. These situations have also created opportunities for individuals such as you to assume key leadership roles in organizations as guiding forces for compliance.

Question:
The senior executive team, the Ethics Review Committee, and the board of directors are concerned about successful implementation of the code of conduct that you are developing for ECG. There has been little focus in the past on widely communicated and consistent ethical standards due to a focus on the company's growth and the assumption that employees would take the ethical approach in all business activities. The firm found, however, that each person's perception of ethical can differ and not all employees behave in a manner that the firm (and likely others) would consider ethical. The soon-to-be introduced code of conduct will provide formal and specific company-wide guidelines, leaving much less room for interpretation or leniency. This is a dramatic shift from past practices, so there are implementation concerns.

To alleviate the concerns of ECG leadership and to provide more direction to your role, you have been asked to present a comprehensive and innovative change management plan to address how the new code of conduct will be implemented. In this plan, you should focus on successful company-wide implementation and acceptance of the policies by reviewing specific implementation steps and identifying who will be involved at each stage.

Please give me ten major points on this to get me started.

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Solution Summary

The solution discusses leadership and ethical decision making.

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Key Points:

Standardization across borders and companies
Change of company culture and flattening corporate structure
Buy-in and example set by upper-management
Include all stakeholders in development of ethical practices
Training that include figurehead, HR, representatives from other countries
Creating a Project Management Team that includes representatives from all stakeholders
Important to clean house and commitment to upholding values to everyone including upper management and
board of directors - replace members for diversity
Creation of a pamphlet for distribution to all employees, vendors, etc.
An IT program as a teaching tool
The CEO must take the forefront and continue to live the new culture.

Below is my basic take on the subject matter:
Innovative change management plan will be developed that outlines who will be involved at each stage. The key to integration will require a change in corporate culture and the need to flatten the corporation structure. Communication and standardization will be required among all divisions, board of directors, and commitment and example by upper management. The CEO needs to be the spokesman for change and needs to show by example all employee and management communication should begin with the new company culture and at the onset of each company meeting. Implementation requires consistency in ethical practices throughout entire company including all subcontractors, consulting personnel, and all vendors as well.
This is a huge responsibility that will requires a Project Management Team to begin by researching each company's history in ethical practices, problems encountered, and current ethical standards in each segment. An investigation and fact gathering of all applicable country's laws, regulations, IPO requirements, each country's reporting requirements, and country ...

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