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November/December 2008 - By Andrew Singer

Cisco Transmits Ethics To a ‘Wired’ Work Force

Companies should not be afraid to be creative with their business conduct codes—or ethics programs generally—says Cisco Systems, Inc.’s Ethics Program Manager Jeremy Wilson.

All too often they are inhibited by the thought that “legal would not like that.” Compliance-related topics are inherently dry, he notes, and companies shouldn’t shy away from seeking new ways “to connect with your code and your employees.”

Revamping the code of conduct

Cisco launched a new business conduct code in mid-January 2008. The roll-out campaign took two months. Although the code encompasses some 60 pages on a PDF file, the text is not dense—the code would run only 12 pages if it were text alone. The expanded length is the result of art and graphics.

Wilson notes that the previous business conduct code “was already concise.” The problem with that document, which dated from the late 1990s, was not prolixity, but language. It was too legalistic. It was a “static” document, one that “sounded like it had been written by attorneys.”

Drawing on the creative services team from mPower Communications at The Network, Inc. (Atlanta), Cisco’s ethics office brought the text down to an 8th grade reading level—a common standard for business codes of conduct—and added art, graphics and an index.

Cisco then conducted 53,000 ethics code certifications within eight weeks, a fast clip—and one that probably couldn’t be duplicated at a non-technical company where every employee did not have a laptop computer, as is the case at Cisco. Initially, the technology company simply e-mailed a PDF version of the code to each employee.

 ‘Ethics Idol’

Cisco hasn’t been afraid to try something new when it comes to raising ethics awareness. The company developed ‘Ethics Idol,’ a cartoon-based parody of American Idol, the television reality show, in an effort to engage employees in ethical decision-making. (Again, the company drew here on the services of the mPower Communications group.)

Featured on Cisco’s Intranet, it presented a series of animated ethics scenarios that are evaluated by judges. Cartoon characters sing about different ethics situations—sales practices, procurement issues, and other common dilemmas. Employees also vote, making their judgment calls on each ethical situation.
The ‘contests’ have also been run by DVD in a live setting. Cisco managers use ‘Idol’ handbooks that explain how to run the contest.

Said Wilson, “Ethics Idol helped raise awareness to Cisco’s employees that each ethical dilemma is not always cut and dried, and if they should have any questions to refer to the Cisco Code of Business Conduct for guidance.”

Cisco’s ethics office was created about three years ago. Earlier, the function had been managed by a lone individual on a part-time basis working out of Cisco’s employee relations office. The ethics office reports through internal audit to Cisco’s board of directors, as does the company’s investigations unit.

At the time of the office’s formation, Wilson was tasked with putting together a “world class” program. He had reason to believe he would be supported in this. The company traditionally treats its employees well. “They don’t settle for the mediocre,” says Wilson.

‘Utilizing the technology’

Manpower, however, would not be abundant. Cisco’s ethics office has at any time between two and five individuals working in it—yet it must get the message out to more than 50,000 employees. “We are utilizing the technology to do this,” says Wilson, including communication instruments like blogs and discussion forums “so we are not answering the same question 50 times.”

Christine Style, who moved to Cisco from the The Network a year ago to become ethics marketing manager, notes that Cisco has options in regard to ethics communications not available to other companies. Corporations like McDonalds and Starbucks, to cite two, do not usually provide employees with Internet access. Most are working in stores or restaurants.

At Cisco, by contrast, every employee has a laptop computer and Internet access. An ethics blog thus becomes a viable communications alternative—one that the company is, in fact, developing.

Prior to the new business conduct code, there had been “some chatter” on the company’s finance blog site about the old code. An employee had gone to look for an answer to a compliance question, and he had come up empty. The document was difficult to read. The language was technical and dense. And so on.

Wilson answered the blog. “It’s interesting that you brought that up….” He continued to use the finance department’s blog for feedback during the developmental phase of the new code, and also during its roll-out campaign.

“We seeded some questions out there.” At times, the ethics manager sought feedback from blog participants directly. Wilson sent emails to them, “Is there anything else you found lacking?”

An ethics department blog is currently “in the works,” says Style; it should be operating before the end of 2008. It will present actual company cases of wrongdoing with the names of malefactors purged. Ethics has asked the company’s investigations group to submit cases for consideration.

“We have to make it interesting to the average user,” not just someone researching a topic, says Style. They want to make the blog sound like it is coming from ethics manager Jeremy Wilson directly, she says.

People find real cases “fascinating,” adds Style. They already use real case studies in their ethics training e.g., “What was the scenario? How much money did it cost Cisco.” And so on. Style notes that Boeing Company has used this approach successfully in its ethics communications program. (See “Boeing Company’s Ethics Improvements Take Flight,” Ethikos, July/August 2006.)

What about the company’s legal department? Aren’t they concerned about this “real case” approach? Could it open up the company to defamation suits?

Wilson said that he has been working “hand in hand” with the company’s in-house attorneys. He had some experience in this area. He worked previously in Boeing’s ethics office. “It goes back to how you sanitize the cases,” Wilson told us. Sometimes you have to tweak the data a bit.

Also, “stay away from things that happened in the last quarter.” Those cases are too fresh in people’s minds—and are more likely to lead to easy identification of the malefactor. Better to use cases from two or three quarters back, says Wilson.

For a blog to be successful there are several tried and true rules, Style adds. It needs to be frequent. (Cisco will seek to change the blog’s content every two weeks, or at least every month.) It has to be compelling. (Hence the actual ethics cases.) “We’re trying to build an audience,” says Style. They also have to archive articles.

The ethics office will manage the blog. It will be open to Cisco employees only. Phase two of the blog will allow people to submit questions.


Cisco has also been developing a computer training module for new hires. The modules conduct a student  ‘review’ not only at the end of the document, but after each section. The idea is to boost the ‘interactive’ quotient wherever possible.

Cisco is seeking to customize its ethics training, too, by geographic region. “Russia is different from China which is different from the U.S,” says Wilson.

It’s no secret, for instance, that there is a lot of corruption in the Russian economy. Bribery is often part of how business is done there. This has to be addressed in ethics training for those employees based in that part of the world.

In some Asian countries—including Japan and China—“you do not report things,” says Wilson. It’s a cultural circumstance. It’s often considered disloyal to report wrongdoing. The company therefore devotes more training time in those areas to explaining exactly how its reporting mechanisms work. If they can put a face on ethics in that part of the world, that helps. In China, Cisco employees know that they can call Jason Beck, a senior manager, because he is based in Beijing, for instance.

Cisco is establishing regional ethics councils in places like China. Ethics issues can get bottlenecked; they don’t get out. With the ethics councils, employees can go directly to senior leaders with their ethics concerns. That should help to increase reporting, Wilson suggests.

The ethics office does not do all manner of compliance training. It does not conduct Foreign Corrupt Practices Act (FCPA) training, for instance. Cisco has a decentralized compliance function, notes Wilson. One group does FCPA training, another does insider trading training, and so on. The ethics office itself does more general sorts of training, like that pertaining to the code of conduct.

A ‘wired’ work force

Few corporations have as ‘wired’ a workforce as has Cisco. Wilson is seeking to engage employees in ways similar to how they are already communicating with each other, such as through texting and pod-casting.

Is it fair to say that Cisco senior management is ‘less uptight’ than managers at other companies?
“They embrace new ideas quickly,” answers Wilson. Many senior managers themselves have blogs. CEO John Chambers hosts monthly ‘birthday breakfasts.’ Anybody who has a birthday that month gets to quiz him (as part of a group) for an hour and 15 minutes. The company is constantly seeking feedback from employees, says Wilson.

As noted, every Cisco employee has a laptop computer. Does that change things significantly when it comes to business ethics?

“Hugely,” answers Wilson. At Hilton, where he also worked previously, few employees had laptops. Many employees, after all, were doing things like cleaning hotel rooms. When they had a new training module they had to mail DVDs to the employees’ homes. Some employees ran the DVDs in the hotel rooms where they were working. If something required online access, however, it would be viewed by those at corporate headquarters—and a few others.

Here it’s different. ‘Techy’ type employees often like to be approached in a ‘techy’ way, suggests Wilson. Ethics marketing manager Style notes that with the Ethics Idol program, “Senior management allowed us to do something a little edgy.” In the ethics sphere, the firm has “led the effort to be creative, to do something out of the box.” Technology just multiplies the possibilities.

Adds Style: “I’m thrilled. We can get an e-mail to every single employee….this is the wave of the future.”

Andrew Singer is Editor and Publisher of Ethikos.
Reprinted from the November/December 2008 issue of Ethikos.
© 2009 Ethikos, Inc. All rights reserved.
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