Ethical Initiatives of global companies

My Ethics Moment!

Today, we have invited, Devray from Cardinal Health, and Alice from Microsoft Japan. From Deloitte, Yoko, Deloitte Tohmatsu Group Ethics Officer, joins, and Nikki, Deloitte Asia Pacific Conduct Leader, will be facilitating this discussion.


Devray Kirkland

Vice President Diversity & Inclusion, Chief Diversity Officer at Cardinal Health Inc.

As a Chief Diversity Officer, Mr. Kirkland is responsible for creating the organization's culture and developing and implementing diversity strategies. He has held numerous human resource management and development roles at multiple companies.

Alice Graham

Assistant General Counsel, Corporate, External and Legal Affairs at Microsoft Japan Co., Ltd

Ms. Graham is the Head of Corporate, External and Legal Affairs at Microsoft Japan for over 2 years, leading professional teams of legal, government, philanthropy, and digital crime under the business-driven compliance. She has over 20 years of experience in legal affairs.

Nikki Scott-Smith

Asia Pacific Conduct Leader at Deloitte Asia Pacific Limited Partner at the Deloitte Australia firm

Ms. Scott-Smith leads the Asia Pacific Conduct team and the AP Ethics Program, aiming to embed a culture where our people and businesses make the right choices and decisions, for the right reasons, at all times.

Yoko Kubo

Ethics Officer at Deloitte Tohmatsu Group Partner at the Risk Advisory Business Unit

Ms. Kubo is the Ethics Officer of Deloitte Japan for 2 years, aiming at embedding the Shared Values and fostering Ethical culture into the firm. Over the past 10 years, she has provided consulting service on risk management and governance.

NOTE: The titles and positions of participants here are as of the date of the interview.

3 March 2021


Nikki: What makes your company actively focus on ethics? Why do you think your company made the move to make a difference?

Devray: It is a business initiative, not just a HR/compliance function initiative. Also, it is not just my job to try to help us do DE&I, ethics or compliance. It’s everyone’s job. We all have a stake in what we are trying to get accomplished.


Alice: I agree with Devray. Ethics concerns every single employee. For example, in Microsoft, we have many privacy regulations, and that is pushed out way down in work of every single employee by what we called “privacy by design.” We know that each employee is the one actually executing the building products, delivering services, and talking to customers, so we ask each of them to own, understand, and design privacy into their own work. “Diversity by design” and “compliance by design” hold the same concept. It’s foundational for us to say when we deliver technology that changes the world, we have a responsibility to help shaping the world. And the only way to do that is not by the centralized function but each individual employee.


Nikki: At Deloitte, we have many different Business Units and this year we combined our Conduct team so we have one team focusing on the ethics strategy across Asia Pacific, they deal with the roll out of the program, investigations, compliance, training and communication. We have Shared Values, which include “Serve with integrity” and “Take care of each other,” and so we are encouraging people to speak up when they see, hear or experience any form of misconduct or behaviors that are not aligned to our values. One thing we realized is that with the number of the people working, it is too much work for one Ethics Officer and one small team in each country to take on the initiative by themselves. So, in order to move things forward, we have developed an Ethics Advocacy Program. In each business, we’ve identified Ethics Advocacy Officers (i.e. Business Ethics Leaders), championing the ethics cause. They are extending the network and spreading the messages within respective business unit. It is an extension of the ethics function, but it’s taking it into business and embedding it into the day to day behaviors

Yoko: It’s been 5 years since we established the Ethics Advocacy Program, and it’s working well. In the previous Ethics Survey, however, we found some comments from employees, saying that the top managers, such as CEO or business unit leaders, have started to focus on ethics, but their direct managers have not changed much. So, our next focus is to cascade the change down to the direct managers on the practical level. I think we are in the right way, but we have more things to do.


Devray: We are understanding that the tone of the top is critical, but as it walks though the organization sometimes the message gets watered down. We are struggling how we match the intensity and the focus from the top with the knowledge from the more junior people so that the middle layer can conduct the communication back and forth in a meaningful way. And we also see a struggle due to a big difference in professional roles and non-professional roles. When we try to communicate and get things to our R&D employees or in manufacturing facilities, it has to be messaged differently so that they can get the context correctly about what we are asking. 


Alice: The middle layer people are focusing on meeting their business objectives, so you have to make DE&I part of their business objectives to get their attention. In Microsoft, for example, we have introduced a system in which employees are evaluated and rewarded when they achieve the diversity of hiring rates. This also makes it easier to track the progress of DE&I in our company. The key is to make sure that the objectives are clear and measurable and owned by the middle layer. On the other hand, when there is a serious incident, we are communicating it widely like “this middle manager lost their job because they did this.” We give the facts and names, although sometimes we cannot due to settlement agreements. In this way, we are implementing measures for middle management from both sides of the so-called "carrot and stick".


Nikki: I’m really interested in the level of transparency you just spoke about. So, Alice, to what extent do you share what happens? Do you share those details with all employees or only with the leadership group? 

Alice: It has been a journey, and it does depend on the case. Let’s take an example of a harassment claim. We do the investigation and share the result with those people involved, and that’s generally a smaller group. For a case of corruption issue that happened years ago and we are finalizing the settlement, we are sharing the details with the whole company such as the name of the partner, employees, the conduct, and the amount of money. It varies because there is sensitivity, and for a harassment sometimes there are settlement agreements that prevents us from giving the specific. But even in those cases, one of the things that we do is actually to take those scenarios to the compliance training or ethics training that is required though we cannot expose the specific so that that will be real and meaningful to the employees.


Nikki: As an organization, we tend to focus on the negative behaviors quite a lot, saying “Here are the behaviors and types of things we don’t want you to do.” However, the Japan firm has done a lot of work in role modeling positive behaviors. They are showcasing people who have done the right thing. It might not necessarily work in different geographies, but it has been well received in Japan. So, I totally agree Tatjana that both sides serve a purpose. 
Moving on, let’s talk about what you have been doing for ethics in your companies, what has been received positively by your employees?

Alice: Our effort really resonates with people when we share the specific details. The notion of ethics and compliance is a little squishy, so we are helping people understand it in their day-to-day life and work. A good episode in daily work helps employees know the right thing to do, while an episode of failure helps them realize that they can speak up even if they made a mistake or even if it did not work out the way they thought it would. By creating such phycological safety, it will promote the virtuous cycle for them to speak up.



Nikki: At Deloitte, we conduct an Ethics Survey each year with relatively consistent questions so that we can monitor how we are doing and compare results. How are you gaining feedback from employees to see if your efforts are being well received and working?

Devray: One of the things we’ve been trying to do is focus groups & listening sessions. They have been very successful and helpful. In a focus group, a senior level leader starts a session, and then participants break up into small groups without the leader, and finally, representatives of each group report discussed topics and insights to the management. The key to this initiative is to create a trustworthy and secure space that maintains anonymity. If it is a regular talking without camera or recording, we get more constructive feedback, and people are more willing to share. Also, we don’t get the same level of feedback when senior level leaders are listening. This method protects the anonymity and shows people the time invested by senior level leaders on this issue.



Nikki: What are you focusing on to really embed ethics into your organization? 

Devray: First of all, I believe it is important to make employees understand Integrity, which is one of the core values of Cardinal Health. In today's enterprise, integrity for customers and service providers is critical for brand building. We also focus on holding people accountable. It is necessary for employees to understand what can happen if they don't follow the rules and how to be accountable. Both of those values need to work harmoniously. You cannot have one without the other. We want to let people know that we are going to handle things according to policies and procedures, and no one is above reproach. Our CEO is also careful when sending messages to employees regarding these topics.


Alice: In Microsoft, we think about ethics and ethical behaviors from three perspectives. The first is engaging the stakeholders, policy makers, and influential people around ethical issues. The second is advocating for ethical public policies. The third is having ethics embedded into our products and services. For example, we have proposed how government agencies should design ethical AI, hearing from stakeholders, academicians, and government policymakers. Our efforts are very much out-reaching, and many are not necessarily about our products, but we believe that sharing ethical opinions is what we need to do and what it means to be “ethical.”


Yoko: Given the things we discussed today, I think we have faced similar challenges. For FY22, we are definitely focusing on the middle layer, cascading down the message from the top management to more junior levels. Furthermore, instead of sending a message that "You can't do this," I would like to send a positive message like "That's a good approach" to empower them. I think the staff is tired of negative messages.


Alice: On the other hand, what I found in Japan is that people struggle with being empowered. They want to be told what to do. They want much clearer, almost step by step, guidelines. In Japan, there is almost a paralysis. If I say, “you are empowered, go do this”, they go “oh, what do I do?” That is one of the big surprises to me after moving from the US to Japan. Empowerment is important, but that does not work in Japan, so the top management needs to lead.


Nikki: Thank you so much for your time. I’m really encouraged by the discussions today and it’s been great to hear what each of you are doing.Our focus over the next few years will be to establish a behavioral mindset throughout Deloitte, empowering employees and the business to make the right choices and decisions for the right reasons at all times.

Editor’s note

The Ethics Advocacy Program mentioned by Nikki in the article starts FY 22 for the AP as a whole, but it has already been established as a Business Ethics Leader and Business Ethics Champion in Japan for several years.  It is wonderful that the case in Japan is further developed as the best practice for the entire AP, and I am proud of it as the Ethics Officer of Deloitte Tohmatsu Group.

Yoko Kubo
Ethics Officer
Deloitte Tohmatsu Group

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