Building a culture of integrity that works

Not long ago, Gaythri Raman, the head of LexisNexis Legal & Professional, part of RELX, in South East Asia, was having a coffee with a long-standing acquaintance in Kuala Lumpur. He was a judge, a client of LexisNexis, who had recently been promoted to the Superior Court. Raman had reached out to congratulate him and he had suggested coffee.

When the bill came – it was less than $1 – the judge said the coffees were on him, but she declined. “I told him, ‘Judge, I know this is a ridiculously small sum, but it’s not about the cost of the coffee. It’s that we are both public figures and I don’t want anyone to draw the wrong conclusion, so I’d feel more comfortable if we each paid for our own coffee.’”

The judge conceded with good humour, and having settled the matter of the bill, each went their own way.

Raman says the incident might seem trivial, but it goes to the heart of how she uses the RELX Code of Ethics in her working life. For her, the code is not only a guide for how to act when representing the company; it also guarantees peace of mind. In a relatively small professional legal community where everyone knows everyone, it’s important to separate personal from business dealings. The Code helps her to do that.

A living charter

The Code of Ethics occupies a very special place at RELX. It is much more than a set of rules. It defines the company’s values and performance. It sets the standards of behaviour for RELX’s 33,000 employees and their business with clients in more than 180 markets. It is a manual for handling conflict and tricky situations. Among many key issues, the Code addresses fair competition, anti-bribery, conflicts of interest, employment practices, data protection and the appropriate use of company property and information. It encourages the reporting of potential violations and prohibits retaliation against whistleblowers. All new employees are trained in the Code and all staff get regular refresher courses. The Code is updated every three years and is subjected to rigorous internal and external reviews. It is, in every sense, a living charter, and the foundation of RELX’s culture of integrity.

It is also part of a rare set-up. Worldwide, only 14 per cent of employees believe they work in an ethical environment, according to the Global Business Ethics Survey. Whereas at RELX, 90 per cent of employees agree with the statement “Where I work, we employ strong, ethical principles in our business practices”. The response, from a recent company-wide employee opinion survey, provides clear evidence of the impact of the RELX Code of Ethics. It sets RELX apart from most businesses worldwide. In the UK, fewer than half of FTSE 100 companies have codes of ethics that are up to scratch, according to research by the Institute of Business Ethics (IBE). Only 46 companies were rated “good” by the IBE, including RELX.

Having a strong code of ethics matters. It encourages work colleagues to respect and trust one another, and it helps to make managers into good leaders. It instils a pride of belonging, and it creates a safe environment for people to speak out, without fear of retaliation, when they see things they don’t like.

Few organisations can say they have this pride and loyalty. Witness the “great resignation” that has followed the Covid-19 pandemic in the US, with nearly one in four workers quitting their jobs. According to the Pew Research Center, the most cited reasons for resigning are a lack of opportunities for advancement, feeling disrespected at work and low pay.

“Employees stay where they feel respected – that is our first principle. The great resignation is not just about pay, it’s also about culture.”
Jennifer Jung, Chief Ethics Officer at RELX

People and pandemics

Covid-19 threw up extraordinary challenges for all organisations, but there were some positives to emerge, too. For example, the pandemic crystallised the importance of having strong ethical values to guide corporate behaviour.

Companies with solid ethical frameworks went the extra mile to support employees and vulnerable customers and suppliers. In an international survey, the IBE found that companies who had comprehensive ethics programmes in place were particularly effective in the pandemic.

With most staff working from home, RELX launched online keep fit classes and an award-winning MindLife programme to balance physical and mental health and keep employees engaged. Elsevier, part of RELX, made Covid research free online in Mandarin and English. It also created a Covid-19 Healthcare Hub with free access to toolkits, expert insights, research resources and Covid-19 guidelines to help clinicians deliver care and information to patients.

“Our employees felt safe through Covid,” says Jung. She says health and safety reports of breaches to the Code of Ethics went down in 2020 and 2021.

The evolution of the RELX Code

RELX introduced its first Code of Ethics in 2006. Comprehensive reviews every three years have allowed the charter to evolve with the times to address cyberthreats, data privacy laws, diversity and inclusion concerns. Jung says the Code “is not a guide for taking a stance on global issues”, although ethical debates in the outside world do end up feeding through into the issues employees care about.

“With the Black Lives Matter movement, we are seeing more reporting of incidences of race discrimination in the US, while in the UK, we are getting more concerns about mental health and psychological safety. The term ‘micro-aggressions’ has begun to appear in reports,” Jung says. “It’s a reflection of what’s going on in the world. I would be worried if these broader social issues weren’t being raised.”

Over the years, the Code has been updated to become more readable and relatable, with real-life examples to help guide decisions. There has also been a shift from compliance – what employees are legally obliged to observe – towards values, exemplified in the company’s Do the Right Thing principles. These are focused on respecting one another; incorporating ethics into actions; growing the business with integrity; and being accountable for one’s behaviour.

There has also been a big drive to increase employee engagement with the Code, with videos, articles and quizzes during Compliance Week and an Integrity Hall of Fame to recognise employees who demonstrate outstanding conduct and commitment.

Vanessa Morris, a strategic account manager at LexisNexis Legal & Professional based in Maryland, US, says this multi-pronged approach has proved very effective at engaging employees with the Code. “I’ve been with the company since 2011 and the growth in learning methods – the new online learning tools, the website and games and trivia quizzes and events – have customised learning and made it relevant to how we engage today.”

Morris is a leader of the DC African Ancestry Network (AAN), an employee resource group at RELX that promotes professional development, community service and networking. She was helping to organise an event with guest speakers who were judges when the question of appropriate thank you gifts came up.

“Our guest speakers were clients of LexisNexis, but they were also giving up their free time to talk to us about the legal profession from their perspective as judges, as women and as people of colour,” Morris explains. “The question of thank you gifts arose because some local and federal government organisations do not allow any gifts at all, not even a five-cent pen.”

Morris wrote an email to the Code of Ethics team and the response came back: no gifts. Instead, the DC AAN took photos and wrote an article about the meeting and celebrated the event on social media. “The judges were happy with that,” she says.

In Kuala Lumpur, Raman says that employee engagement is vital because the Code can sometimes appear intimidating and onerous. “There are many rules and limits on the amount you can spend on gifts and entertainment, for example. I´ve tried to create a safe environment for staff to ask questions about the Code. This opens up avenues to explain why we have it. If people are comfortable, then they will not hide stuff. We need to get people to speak out about the Code, particularly when it doesn’t make sense to them.”

Is it OK to give a box of dates?

During Ramadan in Malaysia, it is the custom to send hampers of foodstuffs to friends and business contacts. At LexisNexis, Raman’s editorial team wanted to know if it was OK to take a box of dates to judges when they visit courts to discuss case law reporting.

She decided to have a meeting about the dates with her team. “I wanted to discuss whether we needed boxes of dates as an excuse to shake hands. What would happen if we went empty-handed? Would judges take offence?” The issue wasn’t the cost, she says, but about the consequences of breaking with tradition.

Together with her editorial teams, Raman came up with an alternative. They created training sessions and roundtable knowledge sharing sessions on case law reporting and judgment writing for judges, especially newly appointed ones. They created a reason for engaging with judges and provided valued support to them without having to bring along hampers or boxes of dates. The training sessions became the pretext for getting in touch with judges.

“We transformed our editorial team into consultants, with a new knowledge-based product that judges would be interested in,” Raman says. More importantly, it was a solution that her team felt comfortable with. She says: “It is only through dialogue that a set of rules can be transformed into a working culture.”

Where things get complicated

The RELX Code of Ethics states that it is “a conflict of interest to supervise or make employment or contracting decisions involving a relative or someone with whom you have a close personal relationship”.

But in much of the world, business would not exist without close personal relationships. Personal and professional networks tend to overlap, opening doors, facilitating introductions and providing character references. RELX understands this is a fact of life and Simon Adams, Risk and Compliance Officer at Elsevier UK, says he gets a lot of questions from employees unsure about whether they have a conflict of interest.

“I think we will never have a clear-cut definition of what we mean by a ‘close personal relationship,’ because it inherently depends on the facts and circumstances in each case. This means compliance officers must analyse each situation, and be mindful of treating people consistently,” Adams says. In India, for example, much recruitment is done through personal referrals, which means several family members might end up working in the same organisation. The best solution, he believes, is transparency. If employees inform their line managers about a potential conflict of interest involving a close personal relationship, then management can decide how the conflict is best avoided. Often, it simply involves removing the employee from any decision-making role involving the other person, business or client.

Elsevier is running a pilot scheme in India in which employees are being asked to fill out a “declaration of interest” form. In it, they are asked to list any person, inside or outside their organisation, who might exert a direct influence over their own careers or business decisions.

“One employee answered ‘yes: my husband’. But when we followed through, it turned out that he had no business relationship with Elsevier. It’s just that she consulted her husband on her career choices – she trusted his advice.” What this goes to show, Adams says, is that employee engagement is vital. “We need to understand how people interpret the Code and what it means to them. There will always be grey areas. That’s why it is so important for employees to speak up.”

Speaking up

Raising ethical issues in any organisation is tricky. Most employees don’t want to ruffle feathers. Many fear they might be sabotaging their chances of promotion, or even their employment, if they challenge a colleague or a senior manager on a point of ethics. The IBE’s 2021 international survey found that only slightly more than half of employees who were aware of ethical misconduct raised concerns, while 43 per cent of employees who did so said they had experienced retaliation as a result. The IBE calls this level of retaliation worldwide “particularly shocking”.

The RELX Code of Ethics expressly forbids retaliation, and throughout the organisation, people are encouraged to speak up. There are several channels through which employees can raise concerns. In 2019, RELX introduced an “Ask a Question” function to its Integrity Line, where employees can ask for guidance or seek clarification on the Code without making a formal report.

“If employees can raise doubts, it allows us to get involved before a breach of the Code occurs,” says Jung. “We can give advice and get involved at a point where real education can happen.” In 2019, the “Ask a Question” channel received 18 inquiries; in 2020, that figure was up to 30. Clearly, staff can still raise questions with their line managers and compliance teams.

The goal, Jung says, is to make employees comfortable about speaking up. “I get more requests to speak to teams about the Code. And anonymous reporting is going down.

This is a good thing. It speaks to the fact that people trust the process and are confident about raising their hands. They know that they will be taken seriously, that appropriate action will be taken, and that there will be no retaliation, even if it turns out that an investigation determines that no violation of the Code took place.”

Measuring progress

A Code of Ethics is only good if it is effective, and to be effective its results must be measured. RELX is one of the few companies that publishes data on the reports it receives, an exercise in transparency that Jung says is needed to engender trust. In 2021, RELX received 311 reports of alleged Code violations through the Integrity Line or through other reporting channels. The company says approximately 52 per cent of those reports were substantiated.

Jung says the number of reports has remained consistent over recent years at around one report per 100 employees, which she says is a little below the median published by Navex, RELX's Integrity Line provider.

RELX also solicits internal feedback about the Code – for example, after training sessions – and external feedback from independent consultants to benchmark its Code of Ethics with others. This helps bring out aspects of the Code that can be improved. One area compliance is working on, says Adams, is the speed with which the company investigates alleged violations to the Code. When investigations cannot be conducted in private, it is important to dispel the cloud of suspicion that hangs over an employee, or take remedial action, as quickly as possible.

But just measuring the incidence of reports does not capture the full benefit of having a strong and effective Code of Ethics. Its real impact can be seen in reduced litigation, in a healthier and happier workplace, in a more motivated workforce, in greater profitability, in being perceived as a good corporate citizen and a trusted brand.

“Culture takes a lot more work than just following the rules,” says Raman. “My goal as a business leader is to put a structure in place that is solid and transparent, and to put the RELX Code of Ethics front and centre of all business dealings.”

THE CODE OF ETHICS IS AVAILABLE TO DOWNLOAD HERE