One of the key company lynch-pins in any FCPA compliance and ethics program is Human Resources. Most HR professional do not think of themselves as on the front lines for FCPA compliance and ethics. However the HR function is plays a  key role in “connecting the dots” for FCPA ethics and compliance. What policy does a company take to punish those employees who may engage in unethical and non-compliant behavior in order to meet company revenue targets versus what rewards are handed out to those employees who integrate such ethical and compliant behavior into their individual work practices going forward?

In the energy industry, (and probably lots of other industries) there is the following archetypal story. It usually is told about a Regional Manager in the Far East or the Middle East who is alleged to have said some along the following lines, “If I violate the Code of Conduct I may or may not get caught. If I get caught I may or may not be disciplined. But if don’t make my revenue numbers for two quarters I will be fired”. If such a story is allowed to percolate throughout the company, employees will feel that all that matters is hitting their revenue targets, not acting in an ethical and compliant manner. Human Resources provides a vital front line function is providing consistent, across the board application of a values core values of compliance and ethics by training and then reinforcing that “hitting the numbers” in a manner which is antithetical to the company’s compliance and ethics program is not acceptable. But this must be done in both words and actions.

The HR Department in any multi-national company has a significant role in not only managing the employee base but in assisting to set the correct expectations regarding FCPA compliance and ethics. Consistent applications of these core beliefs and values will assist any company in remaining compliant and driving home the message that the company takes FCPA compliance seriously.

This story is available in full at houstoninternationalhr.com.