Beyond Tone from the Top
Many companies, including Noble, take pride in their “corporate culture.” At the most fundamental level, corporate culture can be thought of as a set of shared beliefs, norms and values that defines what is important and what is appropriate.
In communicating corporate culture, there is a lot of emphasis on the “Tone from the Top”—as seen in the messages and actions of Noble’s senior management. Just as important is our “Tone from the Middle”—the behaviors and actions of middle management”, as demonstrated at Noble by line management, both onshore and on the rig, in managing their teams and crews.
Strong middle management is the driver at the deckplate for employee engagement and a healthy ethical culture — creating a work environment where employees are committed and engaged, do a good job, and do the right thing. Weak middle management, however, often has the opposite effect.
For example, workplace studies have shown that employees’ loss in confidence of their manager’s ethical behavior can be a predictor of a decline in the overall ethical culture at a company. In addition, research also indicates that employee perceptions of whether or not their company is an ethical company is based on how they view their manager’s ethical behavior. Other studies have shown a direct correlation between job dissatisfaction and unethical conduct; further emphasizing the degree of influence and impact that middle managers can have on their crews and direct reports, as well as on the overall ethical culture at a company.
Employees typically interact with their direct managers or supervisors and may have little to no regular interaction with senior management. An employee’s manager or supervisor is often the sole representation of the company and its values to that employee.
Middle managers also typically receive the most reports of concerns or allegations of misconduct (as compared to other methods/individuals who receive such reports). Employees will often raise concerns or allegations directly with their managers. A survey conducted by the organization, Corporate Executive Board, indicated that “66% of misconduct allegations are received by front-line managers, yet only 57% of these managers feel comfortable addressing employee concerns”.
How a manager handles such a discussion with an employee and how a manager acts on an ethical or compliance concern will have a significant impact on employees and the company.
- Does the manager truly listen to the concern the employee is raising or does the manager appear distracted or annoyed?
- Does the manager maintain his/her composure during the discussion, creating an environment consistent with our “Open Door” Policy in which the employee feels comfortable raising and discussing concerns with the manager?
- Does the manager thank the employee for bringing forward the concern?
- Does the manager address any retaliation concerns the employee or others may have in raising the issue?
- Does the manager appropriately act on the concern—whether it be looking into the concern himself/herself and/or escalating the concern within his/her management chain, the Designated Person Ashore, or Corporate Compliance to look into?
- Does the manager circle back with the employee to let them know that the concern was looked into and properly addressed (for example, only sharing details with the employee as appropriate in line with protecting the confidentiality and integrity of any investigation conducted)?
In addition to appropriately fielding concerns about alleged misconduct, what are some other management behaviors that demonstrate ethical leadership and help to create an ethical culture?
- Talk frequently about Noble’s ethical commitment, elements of our Code of Conduct, and most importantly, our values: Honesty and Integrity, Safety, Environmental Stewardship, Respect, and Performance
- Anticipate ethical dilemmas which may typically arise in the manager’s area of responsibility, for example incident reporting, accuracy in recording activities, etc.
- During the planning process, talk with your team about how our values and ethical commitment apply to the work and specific steps and decision points during the process
- Recognize ethical issues when they do arise and ask questions (i.e. troubleshoot) when the ethical action is unclear; and make decisions consistent with Noble’s values, ethics, Code of Conduct, and corporate policy
- Report concerns about unethical actions/ behavior to senior management, the Designated Person Ashore, or Corporate Compliance.
- Leadership Crucial
Leaders in a rig management position play a crucial role in affirming the ethical culture on the rig--they are the “Tone at the Top” and it is critical to their crews and to Noble that they demonstrate and reinforce exceptional ethical leadership and behaviors.
Why is ethical culture important at Noble? Having a strong ethical culture at Noble is important for several reasons:
- Higher employee morale and job satisfaction, which helps with employee retention and recruiting
- More productive and engaged workforce
- Positive impacts to Noble’s reputation and overall value to the stakeholders
- Prevents and deters misconduct (less lawsuits, investigations, fines/penalties)
In addition, at Noble, we administer a Compliance Survey each year to better understand employee views and understanding of compliance, the effectiveness of Noble’s Compliance Program, and potential opportunities for improvement – in other words, the ethical culture at Noble. It is administered online and on an anonymous basis.