Best compliance and ethics program (small to mid-cap): AMN Healthcare
AMN Healthcare’s ethics and compliance program was honored for the way it has ensured that a focus on ethics permeates the organization. This is done by designating a team of ‘ethics champions’, managers who comprise an ethics and compliance committee that serves as a liaison between the business units and senior management and the board. The committee meets three times a year to discuss ethics issues that have arisen in the business units and to propose changes to policies and practices. Giving business unit managers a sense of ownership of the ethics program is recognized as a best practice in fighting fraud, the judges said.
One element of the program – Speak-Up – encourages team members to report potential miscon- duct, using various avenues including a hotline, email reporting and anonymous reporting mechanisms. Information on how to report is posted in all offices and highlighted on the company’s intranet site. All managers are trained in how to handle such reports.
In employee engagement surveys in each of the last two years, employees rate ethics as one of the company’s primary strengths. That makes sense given that AMN includes ‘ethics and values’ as one of the eight core competencies on which each employee is evaluated every year through the company’s annual review for team members. In the most recent survey, 80 percent of employees say they feel comfortable discussing any concerns they have with their supervisor, while 77 percent say they feel comfortable reporting any unethical conduct without fear of retaliation.
‘I attribute the high ratings to the fact that we are always talking about ethics and we put meat behind it,’ says Denise Jackson, senior vice president and general counsel for AMN Healthcare. That includes publicizing when a process or policy change is made or when an Ethics in Action spotlight is posted on the intranet, highlighting someone who drew attention to the fact that a policy change was needed.
Employees are encouraged to speak with their manager on any issues they have questions about. AMN outlines for managers how they are expected to handle employees’ reports, and managers receive special training on how to conduct dialogue with employees, starting with thanking them for speaking up. When issues reported by employees are more than just matters of perception or have legal ramifications, managers have been trained to follow through with the appropriate action. They are also trained ‘to be sensitive to the fact that an employee may perceive something as retaliation’ even when it isn’t.
The business AMN is in tends to ‘attract good people who want to help people,’ Jackson says. ‘We’re fortunate to have them.’
