The Appearance of Impropriety

When I was at Levi’s, we went through all sorts of trainings led by the Compliance Department. Compliance Departments generally sit within a Legal Department and ensure that employees and the company are following laws and industry regulations. Basically they make sure no one in the company is doing anything illegal. But they also attempt to ensure there are no ethical breaches either, whether or not any law is actually broken.

For Compliance Divisions this process involves designing and implementing training programs that ensure employee practices are in line with laws and regulations. Most Compliance Departments go a step further to ensure employees and the company more broadly are putting practices into place that ensure there is not even the appearance of impropriety or the potential to violate laws and accepted practices.

Whether or not the training is effective, I support the intention: employees need to be educated about laws and regulations and ethical business practices and held accountable for upholding them. I hold myself accountable. Not everyone does without threat of punishment.

The compliance trainings were wide-ranging and ever-expanding. During my decades at the company, I participated in annual trainings including: anti-bribery, how not to harass someone, how not to even appear like you might have harassed someone, how not to be a raging sexist, adhering to tax practices, anti-corruption, anti-racism, anti-nepotism and anti-everything. In case it needs to be said, these were not the official titles of the coursework.