The ethical situation I
was involved with happened many years ago when there were not ethics and
compliance offices or officers. At this
time I was an administrative assistant and part of my job was to create and submit
expense reports for my boss and his direct reports. For the reports I had to submit phone records
and account for only the phone calls/charges for work purposes only. It became apparent very quickly that my boss
and one of his direct reports were in a relationship. From my perspective I had no idea if I should
say anything and even if I did want to say anything I would have no idea who to
report it to. This was a situation in
which a relationship could be bad and have major repercussions in the
workplace. You had one person with
direct authority and power over the other and anything said or done after a
break up could be construed as vengeful and could possibly lead to litigation
In this situation there
are multiple issues. The first being
that there was not good education and knowledge for associates on how to and
who to report ethical concerns. To
address these human resources should have been placing information all over the
building on who to report issues to. In
addition, the information should include verbiage around the safety of
reporting (non-retaliation). If an
Ethics and Compliance Office/Officer had been in place there should have been a
3 step action plan to remediate this issue 1) plan 2) investigate 3)
decision/action
Plan
Once a complaint is
received the Officer assigned to the issue should begin by making a plan. There cannot be a successful remediation of
the issue if you do not know what needs to be accomplished. Work would begin on the issue by determining
who/what to investigate, what kind of evidence is needed, and who needs to be
interviewed. The “what” needs to be
thought out carefully as the issue needs to be defined clearly and carefully so
that the investigation addresses the scope of the issue throughout the process.
From an HR or Ethics
Office perspective the plan to address this situation should include. 1) Collect evidence 2) Discuss situation
including legalities with each invidual 3) Agree upon next steps/consequences
The first step in any
complaint would be to develop an investigation plan. You do not want to see an HR person going to
straight to the participants without having completed a thoruough and well
though out investigation. To be
successful in the investigation the first step should be making a plan. The plan should include w. Once you have the
plan then you can begin to implement.
The who in the situation would be the boss and direct report. The
