Archive for the ‘Compliance’ Category



In our ongoing monthly Tuning in to Trust & Ethics series on elevating organizational trust and ethics, we asked our Trust Alliance members to weigh in on the following question:

Many believe that the HR function plays an important role in building organizational trust and trustworthiness. Do you agree or disagree and why?

Deb Mills-Scofield helps companies create dynamic strategic plans to promote a business-wide innovation mindset.

HR builds trust in how they behave every single day - with each other, their peers and all… Click To Tweet

Obviously, how HR deals with employees’ issues, complaints, and concerns conveys corporate culture.  Confidences need to be kept, gossip discouraged (especially by not participating in it), and root causes addressed.  People need to be held accountable. This applies equally, and perhaps even more importantly, to how HR interacts within their own organization and with their peers.  Double standards are common, but to create sustainable trust, they are absolutely unacceptable. Behavior matters.”

Donna Boehme is an international authority in the field of compliance and ethics.

I have always regarded HR as the beating heart of an organization. Click To Tweet

That’s because the mission and mandate of this critical function, as it’s name suggests, is all about a company’s people- and all aspects of the organizational cycle of their people, from hiring and on boarding/ orientation, to compensation, development and promotion; to retirement/ separation/discipline (as appropriate) of employees It’s obvious that organizations can only conduct business through their employees.  Thus, the manner in which the HR department discharges its mission is absolutely critical to the building of organizational trust and an ethical culture.  For this reason, experienced compliance and ethics professionals regard the HR function as a key partner in all aspects of their work.   It’s my observation that how well Compliance and HR work together on the shared goals of strong ethical culture and organizational trust is the critical factor.  Both functions need to work together to promote employees’ sense of “organizational justice” – probably the most important endeavor of their partnership.

Bob Whipple is a consultant who helps leaders build and maintain trust:

Without question the HR function has a lot to do with whether the culture will be one of high trust, but I think it works in a strange way. I think it is necessary but not sufficient.

If HR is not working with candor and transparency, then a culture of doubt will kindle that is hard… Click To Tweet  

But if HR shows the highest integrity and trustworthy behaviors, it will not be sufficient to create a high trust culture throughout the organization. Reason: I believe trust starts at the top of the organization and cascades throughout the various levels.  The most significant factor influencing a culture of trust is the behaviors of the most senior leader.  A problem leader at any level in the organization can thwart the culture, but a really great leader at the top will root out the problem and eliminate it.  If there is ethical dry rot at any level, the trust will be snuffed out like a candle hit with a bucket of water.

And finally Holly Latty-Mann, a clinical psychologist offers the following advice on HR’s role in building a trustworthy organization:

1) When HR questions management’s decisions that negatively impact the rights of the workforce, they serve equally both management and staff, garnering trust.

2) When HR represents without bias expressed concerns of workforce members to management, trust deepens on all levels.

3) HR is transparent without bias regarding actions staff can take when systems aren’t currently in place to honor legitimate needs, and

4) HR doesn’t play favorites by making themselves the gatekeepers as to who gets what. Click To Tweet

Trust building plays a vital role in the value system and subsequent long-term sustainability of any organization. It must not only be built into the cultural DNA, but must also be practiced and reinforced daily.

Hiring for trust, with the support of upper management should be just as important, if not more… Click To Tweet

The most progressive HR leaders will promote a culture of trust and assist in elevating it throughout the organization.

Barbara Brooks Kimmel is the CEO and Cofounder of Trust Across America-Trust Around the World whose mission is to help organizations build trust. Barbara also runs the world’s largest global Trust Alliance, is the editor of the award winning TRUST INC. book series and a Managing Member at FACTS® Asset Management, a NJ registered investment advisor. In 2012 was named one of “25 Women who are Changing the World” by Good Business International. Barbara holds a BA in International Affairs and an MBA.

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A high performing trustworthy business is a great source of competitive advantage, and that is driven by the Board of Directors. The following are 12 “must follow” strategies for 2017 adapted from our book. 


Boards must pay attention to corporate culture. Culture is the legacy of leadership, and a healthy… Click To TweetBob Vanourek, Triple Crown Leadership

Demand management accountability for the factors that contribute to corporate character. Click To TweetRoger Bolton, President Arthur Page Society

Empower an independent chief compliance officer (CCO) to act as a strong ethical culture leader… Click To TweetDonna Boehme, Principal, Compliance Strategists

Align the business agenda with societal expectations. Build a better world as you build a better… Click To TweetDoug Conant, Conant Leadership

Understand how your stakeholders feel about you. Take surveys, monitor social media and share… Click To Tweet Linda Locke, Standing Partnership

Practice values based leadership: articulate precisely, connect frequently, role-model, sanction… Click To Tweet Charles H. Green, Trusted Advisor Associates

Develop the strategic direction for the enterprise by taking the constellation of all stakeholders… Click To Tweet. Nadine Hack, beCause Global Consulting

See the entity through the eyes of a new employee by attending a live new-employee orientation… Click To Tweet Robert Galford, Center for Leading Organizations

Boards must develop their own robust crisis plans prior to any crisis. Click To Tweet Davia Temin, Temin and Company

Build authentic conversations based on trust and exchange ideas fearlessly. Click To Tweet Alain Bolea, Business Advisors Network

The Golden Rule is the best strategy for Boards to drive C-Suite behavior. Click To Tweet Mark Chandler, Senior VP & General Counsel, Cisco

Review, discuss, share and elevate your company’s “Return on Trust.” What can be measured can be managed.  Barbara Brooks Kimmel, CEO Trust Across America

Get the Board on board in elevating trust in 2017! Click To Tweet. Over 50 more ideas like these are available by ordering the book.

Barbara Brooks Kimmel is the CEO and Cofounder of Trust Across America-Trust Around the World whose mission is to help organizations build trust. Now in its eighth year, the program’s proprietary FACTS® Framework ranks and measures the trustworthiness of over 1500 US public companies on five quantitative indicators of trust. Barbara also runs the world largest global Trust Alliance, is the editor of the award winning TRUST INC. book series and a Managing Member at FACTS® Asset Management, a NJ registered investment advisor. In 2012 was named one of “25 Women who are Changing the World” by Good Business International.
Copyright (c) 2017 Next Decade, Inc.


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Executive Summary of White Paper Recently Published

by Trust Across America-Trust Around the World


Building a trustworthy company will improve both its profitability and organizational sustainability. Supporting this statement is a growing body of evidence showing an increasing correlation between trustworthiness and superior financial performance. Our 2016 report attempts to provide content and context to place trust in the center of more business conversations, to answer the following questions and dispel the myth that integrity and trust are “soft” skills.

  • Why do trust and integrity matter?
  • Can they be measured?
  • Are they profitable?
  • Which sectors are the most trustworthy?
  • Is industry destiny?
  • What are the costs of low trust and integrity and why do they matter as hard currencies?
  • Which companies are some of the most trustworthy and why?
  • How can companies become more trustworthy?

Integrity and trust should start at the top and flow down through the organization. They are not CSR, compliance, HR or leadership “programs” but rather an intentional holistic business strategy adopted by leadership and practiced daily. Vanishing are the days of low transparency, “short termism” and maximization of shareholder value at the expense of other stakeholders.

As trust breaches continue to make the headlines across many major institutions and societies around the globe, organizations that choose integrity and trust as intentional strategies will continue to outperform their peers.

Who will find value in reading this paper?

  • Business leaders
  • Boards of Directors
  • Associations
  • Investors
  • Communications and Investor Relations
  • Corporate responsibility officers
  • Regulators
  • Politicians
  • NGOs

Please register here to request access to the full paper.

Barbara Brooks Kimmel is the CEO and Cofounder of Trust Across America-Trust Around the World whose mission is to help organizations build trust. Now in its seventh year, the program’s proprietary FACTS® Framework ranks and measures the trustworthiness of over 1500 US public companies on five quantitative indicators of trust. Barbara also runs the world largest global Trust Alliance, is the editor of the award winning TRUST INC. book series and a Managing Member at FACTS® Asset Management, a NJ registered investment advisor.

Copyright © 2016, Next Decade, Inc.




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Leaders and their organizations must earn trust before they can build it.

Failure to earn trust leaves the enterprise vulnerable to countless risks. —

Barbara Brooks Kimmel

Trust building can be implemented through the following sequence of actions and initiatives. We call this the VIP Trust Model.



  • VISION & VALUES: Leaders identify, with input from all stakeholders, the organization’s principles or core values. Why does the organization exist and what does it stand for? Write a meaningful credo with buy-in from all silos.
  • INTEGRITY: Practice and regularly communicate the moral principles and purpose of the leadership team and the organization. Hold training for employees in leading with trust in their behaviors and interactions. Lose the “sales scripts.”
  • PROMISES & PROCESS: Ensure that leadership is held accountable for doing what they say they will do, and for regularly communicating the vision, values and promises to all stakeholders. Make this a daily function of your corporate responsibility team in collaboration with compliance and communications.

Implement ways of doing things that translate the principles above into organized group behavior. Internally this includes the hiring and training of employees, structure of meetings, transparency of/fair personnel policies, how decisions are made and accessibility to leadership. With external stakeholders (vendors, customers, community, etc.), trust can be enhanced using quantitative measurement, benchmark and screening “tools” like Trust Across America’s FACTS® Framework.

About the Author:

Barbara Brooks Kimmel is the CEO and Cofounder of Trust Across America-Trust Around the World whose mission is to help organizations build trust. Now in its seventh year, the program’s proprietary FACTS® Framework ranks and measures the trustworthiness of over 2,000 U.S. public companies on five quantitative indicators of trust. Barbara is also the editor of the award-winning TRUST INC. book series and a Managing Member at FACTS® Asset Management, a New Jersey registered investment advisor.

Nominations are now open for the 7th annual Top Thought Leaders in Trust.

Copyright (c)  2016, Next Decade, Inc.

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Organizations and their leaders often find themselves caught in “trust and ethics traps.”

Jes Staley the newly appointed American CEO of the beleaguered British Barclays Bank is one such leader. In fact, as he recently announced in this BBC News Article “I do believe that trust is returning to our institution. But we will never rest, we are never done. We have to focus on building that trust every day.”

Eerily, Staley’s comments have a familiar ring. In the wake of the Libor scandal in 2012 the Bank’s new CEO, an insider named Antony Jenkins also spoke extensively about rebuilding trust. Yet in an all too common response when faced with a crisis of trust and ethics, the Board Chair John McFarlane recently passed blame to regulators for picking on the bank.

We asked our Trust Alliance members to weigh in on the steps Barclays new CEO should take to build trust and ethics, carrying on the legacy of his predecessor.

Leadership Momentum’s Elizabeth Doty emphasizes the importance of building on the company’s new purpose and values, by making clearer, stronger commitments to stakeholders:

Though outsiders can never know a company’s internal reality, Mr. Staley’s comments show that he recognizes that trust is earned by being trustworthy. It is also positive that Mr. Staley’s predecessor, Mr. Jenkins, clarified the company’s purpose and values, and outlined specific behaviors, such as “I honour my commitments.” Still, given the turmoil of repeated leadership changes and reorganization, Mr. Staley and his team are likely to face serious credibility challenges, regardless of their intent.

The purpose of a commitment is to reduce others’ uncertainty, so they feel less risk in trusting us. Making and keeping meaningful commitments is a powerful way to proactively demonstrate trustworthiness. Yet, despite Barclay’s clarification of its purpose and values, stakeholders are still left with their primary uncertainty: How will you make tradeoffs under pressure? “I see nothing to indicate rates and markets will not be rigged again in future or that schemes to enhance bank profits at customers’ expense…could not repeat,” posted one commenter. One solution is to make clearer, stronger commitments specifically related to the side-stepping stakeholders worry about. For example, Barclay’s could commit to doing whatever most contributes to a customer’s goals, or to a level playing field in the market. Though it takes courage, companies that put such a stake in the ground and learn how to deliver a) increase credibility by showing they understand stakeholders’ true risks, b) reduce the potential for mixed messages to staff, c) force themselves to innovate, and d) differentiate themselves in a way that is extremely difficult to emulate. The key will be not to underestimate the challenges of re-shaping their culture to get there.

Davia Temin, a leading reputation and crisis response consultant speaks of the trust challenges continuing to plague most of the largest global financial institutions years after the 2008 financial meltdown.

Rebuilding trust in financial institutions is a complex algorithm that can test the skills of the best financial engineering “rocket scientist.”  

Far from simply making a pronouncement of one’s intent (although that can be the first step), the organization needs to first deconstruct all the elements that went into building trust in their particular firm in the first place, analyze all the things that went wrong, and then construct a plan to overcorrect the breaches. Because simply fixing them will not rebuild trust, it will only, maybe, stop the erosion. 

But this is seriously hard work. Barclays, as most banks, has a number of critical audiences, each of whom needs a different set of fixes in order to begin to restore their trust. And some of those fixes are in direct conflict with others. Individual customers, shareholders, institutional clients, counterparties, regulators and legislators in every country in which they operate, and even the public at large must each feel that the bank puts THEIR INTERESTS in front of its own. Because it has been the self-dealing aspect of financial institutions’ behavior that did the most damage to their reputations and caused the greatest loss of trust.   

So, to rebuild trust, Barclays and others will need to show their audiences that the bank puts them first…and that’s a hard thing to do and remain profitable. But it is almost impossible to make such a promise and then ignore it, or to fail in its announced attempt. So, now that Mr. Staley has thrown down the gauntlet, perhaps he can get his financial product rocket scientists to reverse-engineer all the elements that went into the losing of public trust, share them with us all, and then announce how he will redress them, one by one. That, indeed, just might work, and would be my prescription.”

And finally Bob Whipple of Leadergrow reminds us where trust starts in all institutions.

It sounds like a lot of problems have been swept under the rug for some time and are impacting all facets of Barclays. I applaud the resolve to rebuild trust in the bank and the candor at admitting the many unpopular steps it will take.  My advice is to recognize that rebuilding a culture starts at the top and works its way down the organization.  Establish an understanding that it is safe for people to tell you the things that are hard to say. Do not punish people when they bring up issues that are uncomfortable or difficult to address.    

Similar to Barclays many organizations find themselves in trust traps because they hold on to the notion that trust and ethics are “soft skills.”

And because trust is ignored or taken for granted, its decline continues across all major institutions. Some of the warning signs of low trust include:

  • Disengaged boards with minimal diversity- not only must the board be “on board” with the mission and vision of the organization but research, including our own points to a correlation between high trust organizations and gender diversity.
  • Frequent crises- identifying core values, practicing and reinforcing them daily heads off many “would be” crises. Leaders who view trust as “soft” often find themselves spending the majority of their time putting out fires instead of improving their culture.
  • Short-term profit maximization at all costs including layoffs and job cuts as a first line of defense- it’s not unusual for companies like Barclays to think the bleeding can be stopped by cutting jobs and divisions, but these are simply bandages and they never cure diseases.
  • Decreasing CEO tenure and increasing compensation packages tied to quarterly earnings- try tying CEO compensation to some point in the future (3-5 years) and suddenly the focus changes from the short to the long term.
  • Increasing regulation (and scrutiny from regulators) and larger legal and compliance departments- as we have discussed in the past, trust simply can’t be regulated. It’s voluntary.

Fortunately the most progressive organizations have begun to recognize the strategic advantages of a high trust culture.

  • Fewer crises and the ability to recover more rapidly
  • A large trust “bank account”
  • Faster decision making and improved execution
  • Higher employee engagement
  • Higher customer loyalty and retention
  • Greater innovation (high trust fuels high innovation, not the other way around)
  • Increased long-term profitability

The trust and ethics crisis at Barclays will not end until insiders, beginning at the Board level, not only accept blame and take responsibility, but also put actionable measures in place to clean up the culture. Will Jes Staley be the CEO who turns Barclays around? Will he walk the trust he is talking? What do you think?

Tuning in to Trust & Ethics is a new monthly column of Trust Across America-Trust Around the World’s Trust Alliance compiled by Barbara Brooks Kimmel

Another version of this article first appeared on the FCPA Blog.

Part I:

Part II:

Copyright (c)  2016 Next Decade, Inc.




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The media’s coverage of trust is gaining momentum — but the headlines are still fuzzy. It’s not hard to find examples that talk about trust as an adjective, verb, and noun, but that all fail to frame or define for readers what the word “trust” really means.

Consider the following headlines from just a couple of days in February:

When Chicagoans Don’t Trust Police, the City Suffers, Chicago Tribune, February 3, 2016

Do You Trust Taco Bell Enough to Blindly Pre-Order a Mystery Item From Them? Probably Not. Paste Magazine, February 3, 2016

In Flint water crisis, the biggest problem to fix may be trust, Christian Science Monitor, February 1, 2016

Are Chicago’s police officers untrustworthy, or is it just that Chicago’s citizenry are scared — or both? Do you trust Taco Bell to use high quality ingredients enough to order a “mystery item?” With which stakeholders is Flint attempting to fix trust?

So what EXACTLY do we mean when we talk about trust?

Read more in this article published yesterday on the FCPA Blog.




It’s almost Week #4 of 2016. This is the fourth article in a series of weekly ideas to elevate trust in your organization, pulled from our third annual 2016 Trust Poster, 52 Ideas That You Can Implement to Build Trust.

This idea is offered by Mark Fernandes. As Chief Leadership Officer at Luck Companies, Mark has been charged with taking its mission of Values Based Leadership (VBL) around the world. @MarkSFernandes

Build cultures of commitment vs. compliance where choices are guided by values not policies.

For leaders, trust and relationships are the means and end of our work. Over the course of my career I’ve found that with them, all things are possible. And much like many other things in work and life, it’s what you do before you do what you do that matters most in building trust and relationships; and ultimately cultures that are guided by values and rich in commitment, vs. those that are guided by policies and steeped in compliance. As such, I would recommend the following:


By definition authenticity means something is genuine or real, and worthy of acceptance or belief. Kouzes and Posner subscribe “people won’t believe in the message until they believe in the messenger.” 


Booker T. Washington said, “few things can help an individual more than to place responsibility on him, and to let him know you trust him.” 


My version of this is to love your employees to death, give them something to believe in, and obsess every day about them becoming everything they are capable of becoming.


People want to know you are completely there with them, in this moment. Pour yourself into their lives and catch them in the act of doing extraordinary things. 


Employees place their precious lives in our care, tread lightly.


How many readers took took the advice offered in January in our Weekly series?

Week #1 Kouzes & Posner 

Week #2 Bob Vanourek

Week #3 Barbara Kimmel

Ignoring organizational trust is similar to swimming in an ocean with no lifeguards on duty. Do so at your own risk!

Barbara Brooks Kimmel is the CEO & Cofounder of Trust Across America-Trust Around the World whose mission is to help responsible organizations build trust. She facilitates the world’s largest membership program for those interested in the subject. Barbara also serves as editor of the award winning TRUST INC. book series and the Executive Editor of TRUST! Magazine. In 2012 Barbara was named “One of 25 Women Changing the World” by Good Business International.

Copyright 2016, Next Decade, Inc.




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