The Office of Government Ethics offers a worthy Instructor Development program:
The IEG will offer a semi-annual instructor development program for experienced agency ethics officials. Successful completion of the program will qualify attendees to teach IEG-created courses to Executive Branch ethics officials for IEG credit. Applicants may select among several available courses, including: the New Ethics Official Certificate Program; Introduction to Conflicts of Interest; Public Financial Disclosure Review; Gifts from Outside Sources; and Conflict-Free Post-Employment Activities.
Successful applicants must commit to attending all required sessions for each course selected, must have significant substantive ethics experience, and considerable demand for ethics official training within their agencies. Details about the IEG instructor development program and application information can be found on the IEG MAX site.
Standards of Ethical Conduct for Employees of the Executive Branch section 5 C.F.R. § 2635.101(b)(12) makes employee private debt a matter of government concern:
(12) Employees shall satisfy in good faith their obligations as citizens, including all just financial obligations, especially those—such as Federal, State, or local taxes—that are imposed by law.
Failure to pay a court-ordered obligation can be a basis for disciplinary action: OGE advisory opinion 94×9: Executive Branch Employee’s Obligation to Satisfy Just Debts.
A USA.gov post on credit counselor resources might be useful for managers or DAEOs counseling an employee with debt issues.
“Entitlement Syndrome” refers to a belief by employees, usually senior employees, that their position entitles them to certain perks. A 2012 Washington Post article on allegations against three Army general officers provides multiple examples for use in training, including this:
On Feb. 14 he sent the following e-mail to an aide: “Might you be able to stop by a florist and pick up a small bouquet of spring flowers for me? Not extravagant at all — just a small not very expensive bouquet.” The aide offered to get it and asked where the general would like the flowers delivered. Ward responded: “Can you have in the limo pls — trunk. Tnx”
Examples like these may have much more teaching value than examples like the high-ranking EPA official who in effect stole hundreds of thousands of dollars by claiming to be an undercover CIA operative. Few employees would ever dream of that type of fraud, and those few are unlikely to be dissuaded by an ethics briefing. On the other hand, many high ranking officials–ones we otherwise would consider honest and capable–succumb to the temptation to take advantage of abusing subordinates.
Will new “Chief Learning Officers” improve federal training? Government Executive weighs in:
Before the CLO position was created, agencies would go out and purchase the training and learning vehicles they needed for their staff without any single strategic vision. The lack of coordination often led to program duplication, which sucked needed funding out of shrinking budgets. Not only that, but lack of clear goals left agencies without a single vision of future workforce and learning needs.
Any solution to the challenges ahead will need to start with CLOs preparing the federal workforce with the tools they need to adapt. The Government Business Council, the research arm of the Government Executive, was compelled to contribute to the conversation around this unique challenge and completed an extensive study on the character of chief learning officers in the federal government. According to the study of over 400 federal managers, 32 percent of them indicated that their agency does not even have a CLO. Of the agencies that do have a CLO, only 30 percent reported that their CLO encourages a culture of learning.
Most federal ethics training is conducted by lawyers. Most of the people being trained are non-lawyers. Problem? Tom Fox thinks so:
One often hears or reads about complaints that compliance training is dull, nay even boring. I mean, how many times can you expect someone to be lectured to on the riveting subject of the Foreign Corrupt Practices Act FCPA or even the UK Bribery Act? Coupled with the legally spellbinding subject, the sessions are often led by lawyers who are training non-lawyers.
While some lawyers are up to the task of making their training engaging, in my experience this is a challenge for many lawyer ethics trainers. A possible solution discussed here previously is greater sharing of ethics training materials. Rather than designing their own training materials as a sort of cottage industry, trainers, including lawyers, should adopt high quality training materials.
Better awareness is another approach. If you are a lawyer, don’t assume that if you understand an explanation, your audience will understand it. Solicit feedback from on your materials and your delivery before you go into “production mode” with your training, and afterward. Most important, learn the difference between talking down to your audience (to be avoided at all costs), and explaining complex things in a way every audience member will understand.
Linda Fisher Thornton highlights one of the most important questions for federal ethics trainers:
If we focus just on compliance in our ethics training for leaders, we are aiming too low and we will always be scrambling to catch up as laws change. How can we move beyond just complying with laws (the minimum standard) to leading ethically in organizations (optimal)?
via Compliance With Laws Isn’t Ethical Leadership (There’s More) « Leading in Context.
The late New York mayor Ed Koch‘s trademark catch phrase was “”How’m I doing?” He would stand on street corners and ask random passers by.
Few of us feel Ed Koch’s compulsive need to obtain feedback, but most would benefit from learning more about how our audiences perceive us. A sample Evaluation Form in MS Word format is attached. It is based on one used by OGE trainers.
Is mandatory ethics training a good idea? Is this just another way bureaucrats waste time? Well, not really. The recent story that Reuters has begun requiring all its reporters to take ethics training caught our eye, but this is only one of many private companies to require ethics training.
In fact, there is a whole cottage industry of private companies that specialize in providing ethics training. As one, Inspired eLearning explains:
Enron is perhaps the most highly publicized case of corporate malfeasance in recent memory. The actions of Enron executives collapsed a company, sent individuals to jail and saddled them with hefty fines, cost shareholders an estimated $43 billion in losses and led to catastrophic losses for Enron employees, many of whom had their entire retirement savings tied up in company stock.
In the wake of Enron’s spectacular collapse, a copy of the Enron code of ethics was one of the hotter items offered for sale on eBay. “Never been opened,” quipped a seller and former Enron employee whose unopened policy proved that having a code of conduct is not enough.
If your company has a written code of conduct, you’ve taken a critical first step toward preventing ethics and compliance lapses. But printing copies of your code and posting them or passing them out to employees is not enough. To be effective, a code of conduct must be part of a larger effort to promote company-wide compliance with the code.
Amen. It’s absolutely not enough to have ethics rules. More is needed, whether in the public or private sector.