A fatal affair
Before #metoo women thought that sexual harassment was just this one bad story that had happened to them: shocking, confusing, better to just forget about it. Organizations also thought that it was just the occasional case: Annoying, complicated, tricky to deal with, you do not want to know.
After #metoo, organizations and women had to realize, that sexual harassment is endemic. It happens all the time, to everyone and it is systemic especially for cultures that are male dominated, hyper competitive, and forgiving when it comes to bad behavior. In a nutshell, corporate cultures that are characterized by fear and where ethical problems are swept under the carpet of organizational silence. Exactly that kind of culture a good management of ethics and compliance wants to avoid at all costs!
Consequently, my thesis here is: companies that have a system in place that effectively deals with sexual harassment, will also significantly improve their integrity culture. This is why compliance managers need to get the topic out of the taboo zone and deal with it proactively.
Let me explain why:
If companies want to create a robust culture of integrity where speaking up on ethical challenges is save and worthwhile, they need to take care of organizational justice. Only if I have the impression that my company deals fairly with its coworkers, I will have the psychological safety to speak up on sensitive issues. Sexual harassment is an extremely unfair behavior that keeps women small and deprives them of a work environment where they are treated as equals.
A company that tolerates sexual harassment or that does not deal with it in a decisive way, jeopardizes the perception of fairness and organizational justice and thus also drives ethical issues in general into the underground. If a company does not take care of safeguarding its employees from being harassed, all talk about ethics and compliance becomes less credible.
What does a holistic prevention approach look like?
Sexual harassment is a workplace problem that is widespread and persistent. It is deeply ingrained into organisational power structures. Nevertheless, organisational interventions often stay disparate and uncoordinated and deal with it on an individual case level. This approach is not effective, because if a problem is systemic, we must resolve it in a systemic and comprehensive way. In fact, like in any good ethics & compliance management you need a management system if you want to have an impact.
Surprisingly, the things you need to design an effective prevention program for sexual harassment are remarkably similar and highly compatible to the components of great E&C programs.
A blue-print for such a three-level prevention framework comes from one of the top voices on workplace discrimination, Prof. Paula McDonald:
Primary preventions strategies
aim at the avoidance of sexual harassment: remove causes, prevent risk factors, enhance protective factors. The main tools for implementing these prevention strategies are policies and training. The key foundation of all primary prevention strategies is the creation of an informal speak-up culture that makes I possible to address inappropriate conduct and disrespectful behavior early-on.
Immediate Response Processes
usually concern reporting procedures. The creation of reporting structures for sexual harassment that the men and women in an organization find trustworthy, is challenging. Women who report sexual harassment often experience hostile and adversarial reactions (protecting the organisation and not the victim) and a lack of confidentiality and objectivity. They are afraid that speaking up will harm their career and there will be no consequences for the harasser. Furthermore, we are typically dealing with the challenge of low-quality evidence (the typical “She-said-He said-situation”). Consequently, companies need to adapt their reporting systems to these special challenges.
The final element of this comprehensive framework is often missing in other approaches that stop after the resolution of a case. In this victim-centered approach it is crucial to minimise the impact for the victim e. g. by restoring health and safety and preventing further perpetration and retaliation (e. g. lower performance ratings and promotion rates). The prevention of retaliation may require a long-term and proactive follow-up of both the complainant and the subject.
The constant monitoring of risk factors is part of these long-term interventions that should turn the overall preventions system into a process of general organizational learning and development.
Like all best practice E&C programs, this framework aims at sustainable, pro-active and long-term prevention that wants to contribute to the larger context of organizational justice and the creation of a cooperative work culture where everybody thrives. Since sexual harassment is such a complex and sensitive issue, I see it as a cornerstone topic of ethics management. If you manage to get this right, it will be much easier to also get all the rest right!