Corruption costs the global economy an estimated $3.6 trillion a year. This figure hints at a daunting inference: business-as-usual in anti-corruption may not be working.

While traditional approaches have largely been rules-based, emphasizing policies and trainings aimed at curbing misconduct, increasingly practitioners have recognized the important role that organizational values and culture can play in shaping behavior. Regulators not only agree, but are calling for the measurement of these efforts.

For instance, Kenneth Polite Jr., the assistant attorney general and head of the Department of Justice's Criminal Division, recently said, "We are also interested in how a company measures and tests its culture-at all levels of seniority and throughout its operations-and how it uses the data from that testing to embed and continuously improve its ethical culture."

R&G Insights Lab members Zachary Coseglia, Amanda Raad, and I recently sponsored and contributed to Transparency International UK's latest report, Values Added. The report explores what it means to take a values-based approach to anti-corruption and offers recommendations on how to do so and measure progress.

Taking a values-based approach means ensuring that the core values of ethics and compliance permeate every aspect of the organization, ranging from the hiring process and incentives, to the daily practices and behaviors of employees. And, by definition, it means that efforts to shape compliant behaviors are not just about rules, but also the why behind the rules. This perspective is informed by decades of research in the behavioral sciences documenting the power of values and the cultural context in influencing a person's behavior.

As the report suggests, the first step to implementing a values-based approach is measurement. A data-driven and human-centered cultural assessment can be conducted to understand where the organization's values and culture are currently. This provides a benchmark against which progress can be tracked.

Conducting a cultural assessment involves analyzing both existing data, such as mission statements, communications, and policies, as well as collecting new data, such as through interviews, focus groups, and surveys. To begin, it is essential to understand the organization's values-both explicit and implied-and how those values are being communicated and institutionalized through policies and practices.

  • What are the incentives, and how do they promote and reward ethical behavior?
  • How do ethics and compliance feature throughout the hiring process, trainings, and performance reviews?

Next, the assessment can look to how people are actually behaving.

  • Are leaders walking the talk?
  • Do people feel safe speaking up when they witness misconduct?

This assessment can be repeated to track progress as steps are taken to influence the culture.

Marrying a values-based approach with a rules-based approach offers an exciting new take on anti-corruption. Taking a values-based approach doesn't mean that we do away with rules, rather, it ensures that we use a broader set of tools to connect with people in ways that shape behavior and drive more effective decision-making. This report is important reading for anyone interested in leveraging the power of values and culture in shaping compliance and ethics.

R&G Insights Lab is the legal industry's first-ever offering to focus on analytics and behavioral science. It is a global, integrated, and cross-industry advisory service that combines the dynamic legal team of Ropes & Gray across the globe with world-leading experts in analytics and behavioral science - along with a healthy dose of creativity.

Transparency International is the world's leading non-governmental anti-corruption organization.

Originally published 24 May 2022

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