Your organisation’s reputation is everything. Your clients use your services because they believe you can provide valid and impartial results. Even a small fracture in that belief can cause huge reputational damage. There are behaviours your staff know to avoid such as bribery, and outright fraud, but what about circumstances your staff hadn’t thought of as problematic. Do your staff know how you expect them to behave or react in these difficult situations? Is your company culture conducive to open reporting of questionable behaviours?
If you notice potential conflicts of interest it doesn’t mean game over for your business. However, you do have to demonstrate that you have minimised the possibility of improper influence.
You should consider scenarios your staff might encounter, provide guidance to staff on how to react, and have mechanisms put in place to identify and address potential conflicts of interest. Mitigation of risks to impartiality could include a range of actions ranging from restructuring roles and reporting lines of staff, to maintaining contemporaneous, clear and robust records.
For a lot of business owners, a shift in thinking is required from ‘I trust my staff’ to ‘I trust my staff, and I can also confidently demonstrate their integrity”.
So what are some of the potential threats to impartiality you should be considering? And what can be done to mitigate these risks?
First let’s consider your organisation.
Where possible your organisational structure should reflect clear separation of activities that could pose conflicts of interest, including:
Relationships of your organisation with parent companies and/or jointly-owned entities;
Activities between departments who do potentially conflicting actvities.
For some organisations, staff have responsibilities that inherently conflict. For example, your staff may be at client sites, inspecting and/or testing items, then repairing and/or replacing on the spot.
Is it possible a client could accuse you of failing items unnecessarily so you can sell them more product? Absolutely. So make sure:
Staff are competent to make difficult conformity determinations;
A review process is in place to monitor results being released to clients;
Records (including photographs) are indisputable;
Quotes for replacement items are clear and communicated;
Your client has clearly agreed to the arrangement.
Consider risks to impartiality on a more personal level.
Both consciously and unconsciously, humans have tendencies to bend rules for our own self-interest.
Consider:
financial interests;
personal relationships with external organisations such as clients, suppliers and/or subcontractors.
It is important for staff to divulge any kind of connection that could be perceived as a conflict of interest. Policies and processes can be useful in prompting staff to identify potential conflicts.
Open discussion with staff and clients about these issues is vital. It might also be appropriate to allocate particular projects or clients to staff free of perceived conflict.
An aspect often overlooked when considering staff/client relationships is the familiarity bias. We are all wired to make assumptions based on past experiences, which make us less likely to be thorough and impartial the more familiar we are with a client site. You want your staff to develop good professional relationships with clients, but you can’t have that affect the integrity of the results.
Some suggestions for ensuring results remained unbiased:
Defining and communicating a code of conduct;
Maintaining a culture of integrity by training, re-training and discussion at regular meetings;
Open discussion with staff and clients, re-enforcing the importance of valid results for both your business and your clients;
Independent review of results.
Lead by example.
What does this even mean in the context of code of conduct?
Management need to avoid putting pressure on their own staff which might compromise their ability to produce valid results, leading to shortcuts being taken, financial incentives to complete more jobs in less time and taking on work without the necessary resources.
Management are responsible for creating a culture of integrity by actively implementing policies and processes that support staff to do their jobs properly.
Management are responsible for supplying appropriate resources, training, equipment and facilities.
Undue Pressure.
Unfortunately, the uncomfortable scenario of a client pressuring for a ‘pass’ result must also be considered. Staff will likely experience pressure from clients in some form or another, particularly if they are the only representative on the client site. The client doesn’t want to hear a fail result, and that’s understandable!
Your job is to anticipate these sorts of situations and provide clear guidance to your staff on how to behave, including how to report such incidents.
Your staff must also be equipped with robust knowledge of relevant standards, and be able to politely explain the reasons for the failure with unwavering confidence.
Staff also must understand the consequences of altering results including to your organisation’s reputation, potentially public safety, and personal and legal repercussions.
In Essence...
There’s a lot to digest when you start looking into risks to impartiality, and I certainly haven’t covered it all in this article.
Remember:
Proactively anticipate risks to impartiality and put in place preventative measures;
Review risks to impartiality on a regular basis, as part of your management review, contract review process and when there are significant changes in your organisation that could affect impartiality;
Communicate the importance your organisation’s commitment to impartiality.
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