During a recent PLI conference, James Comey, the general counsel of Lockheed Martin, described several ways in which that company impresses on its employees, continually, the importance of ethical behavior. Comey’s law department supports each of these activities.
A monthly newsletter to all employees contains a “police blotter” on the last page. It lists the ethical infractions of the previous month, albeit with names concealed.
Every month the company circulates an “Integrity Minute,” a short video in which actors portray an ethical dilemma.
Every year the company surveys its employees. One question is “Did you see possible misconduct?” The next question is “Did you see possible misconduct and not report it?” Leadership of the company wants to spot any trends in the answers to either question.
The company also maintains an 800 number for employees to call and report problems. Comey mentioned, however, that no one in the legal department screens those called-in reports. Lawyers step in only if the Ethics Department invites (See my post of Dec. 31, 2006: at Raytheon, legal is almost always involved with a hotline call.).