This profile is the latest in a series of weekly conversations with executives at U.S. public companies who are currently involved in establishing and developing compliance programs. An index of previous conversations is available here.

Describe your job for us.

My job is to assist the 32,000 people who are part of the various Deloitte entities in the U.S. to be aware of the ethical issues they face on a daily basis. I try to provide an environment that not only commits our people to do the right thing—despite the significant pressures they encounter to do otherwise—but also to have the moral courage to speak up if they see something that’s not right, whether it’s within our own shop or in a client situation.

What specific duties do you have?

Well, I break it up into the tangible things we do and the intangibles. The tangibles are our code of ethics and professional conduct. We revised our old code of conduct into a new code of ethics that’s a very personal document. It transcends the different functions within our firm, and that’s important to understand; under the umbrella of Deloitte & Touche you have auditors, tax people, consultants, and various subsets within each of those. We need to assure that when people look at the code, they don’t think it’s just for the auditors or someone else. This is for everybody in the organization.

We also enhanced our ethics training. We created two new courses, one online and one in the classroom, based on real-life situations that people face every day. They were developed in concert with the learning directors from various functions within the firm. We’ve had tremendous response to those.

We also implemented a communication vehicle known as our help-line. We don’t use the word “hotline” because we try to promote this to our people as a way to assist them in getting answers before the fact. We want to have them be proactive in seeking guidance. If they do have something to report, they can use the helpline to do that too.

And the intangible items?

The intangible things surround communication elements. You can create posters to keep in front of our people, which we have done. We have email messages that go out to employees—again, really to keep ethics at the front of their minds, and to say that they have choices and vehicles available to help them make the right choices.

More importantly, the messages that go out from the leadership of the firm keep us in constant communication with our people. In fact, in some cases people say they get too many emails and voicemails. But we’ve asked our leadership to make sure that in most of their messages, there is a place to talk about integrity and ethical issues. They’ve embedded those in most of their live presentations and in the voicemails and emails they send out to people. That’s what tries to create the environment for our people that they’re part of an ethical culture.

Who helps you shape those messages for the rank and file?

I have direct access to the CEO and the board of directors, as well as the executive committee of the firm. We have a group known as risk-management, which deals with all the practice issues you’d have at a public accounting firm. But as far as ethics and compliance are concerned, we do have direct access right to the top of the firm. We report to them regularly on what our plans are, where we’re going, what type of communications we’re going to do.

What sort of information do you present in these reports?

We prepare what I call the “ethics and compliance dashboard.” I try to get the key metrics about what we deal with, whether that’s the number of calls coming through the help-line, or the types of calls and issues raised, whether they were anonymous or not. We also give an update on our people attending required ethics training and other matters of significance. In fact, I just did our quarterly meeting with our CEO this week; I have sessions with him just to get the flavor of what’s going on. He wants to know what we’re hearing, so that if he needs to address an issue he can do so.

How does Deloitte staff its ethics and compliance function?

The ethics and compliance group is composed of two sections. The compliance group itself deals with licensing matters, independence, professional education, and personnel issues such as having enough people to ensure any rotation policies can be observed. That’s a group of about 45 people, and they are pretty much immersed in making sure we have these monitoring and auditing activities so that people are doing the right things. They also serve as a consultation base for our people when they have questions like whether they need to get a license in another state, or how to maintain independence.

The ethics group is about four people right now. It will probably be growing to about six by the end of this year. These people act as subject-matter experts. One is a help-line administrator. Our job there is to leverage off other subject-matter experts throughout the firm. We coordinate all our activities either through the HR people, our legal group, our professional-practice group, our training group. We don’t need an ethics group of 50 people or to develop our own training programs; we sit with our training people within the various functions and help craft the programs we want to do. We use internal audit to achieve resolution to some of the investigations we initiate, and we call on our HR people with issues that come through the help-line.

Deloitte has a diverse, far-flung workforce. How do you ensure your training courses resonate with front-line workers?

We went about that process by getting a committee that represented all the functions within the firm. We solicited from them the types of things their people encounter on a daily basis. These are the issues in their faces all their time, so we develop training that surrounds those things. We’re also doing that as we go forward for additional training. This is something that will go on throughout people’s careers, and we’ll tailor it based on the types of issues that our people run into.

On a quarterly basis I meet with the regional managing partners at our nine regions in the U.S. We have a call so I can update them on what we’re doing, and they update us on what they’re seeing in their regions and how we can assist them.

“Ethics” is a much softer target than compliance. How do you benchmark it?

Well, besides trying to monitor unsolicited comments we might get from people in the firm, we sent out a benchmarking survey on awareness and appreciation for ethical matters before we even launched our new program—just to see if we could get a baseline of how aware people were of ethical issues. We surveyed, at random, 3,000 people within the firm. We’ll do that on an annual or semi-annual basis to see what attitudes people have …

How aware are people? What appreciation do they have for ethics? Do they believe they’re in an ethical culture? Is that what they hear in messages from the leadership and their colleagues in the field? That’s what we try to measure in these surveys.

What’s your typical day like?

A typical day is very busy. Usually a lot of meetings have to take place, and there are a lot of coordination efforts. Those meetings also contain a lot of development we’re working on; we’re constantly asking, “What are we going to do tomorrow?”

I also get a number of phone calls directly, not just through the help-line, from partners as well as managers and staff around the country. My name and phone number is published, and they have the right to call me directly.

What are your top priorities for the next 12 months?

At the top of my list is to make sure we go into the next stage of our training programs. It’s something we’re embedding into our “milestone” training throughout people’s careers. As people advance in our firm, they go to various training seminars on an annual basis to prepare them for that next step they’re going into. We take a slice of that training and embed two hours of ethics and compliance training for that level of person, in that function, to keep the message fresh.

There will always be new compliance items that pop up. We are now a regulated business with the Public Company Accounting Oversight Board, and that brings all sorts of complications. There will always be things we have to deal with.

Thanks, Harold.

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