Innovation in Corporate Ethics

The Ethics Resource Center (ERC) recently announced that Nancy Higgins, vice president and chief ethics and compliance officer at Bechtel, one of the largest privately-held engineering, construction, and project management firms in the world, has been awarded the Carol R. Marshall Award for Innovation in Corporate Ethics (ERC 2014).

Higgins received the award for “actively promoting best practices across the ethics field and for her demonstrated “flair for innovation in program design” during her 20-year career in the ethics field. What can we learn from Higgins and Bechtel?

It’s not just common sense

In a 2013 interview, Higgins stated that it’s important that everyone understand they are expected to do the right thing, but that “you can’t just rely on common sense when dealing with a really complex series of laws and regulations ….” It’s important to provide employees with training in specific compliance and risk areas that apply to their jobs (DiPietro 2013).

Training is ongoing

Again from the DiPietro interview, we learn that all non-manual employees worldwide are required to take an online course about the Bechtel code of conduct within two weeks of joining the company. Within 60 days they must take additional courses in the compliance and risk areas that apply to their jobs, but that is not all the training that occurs. The ERC announcement specifically acknowledges Higgins’ development of a training initiative called “Ethics Awareness Workshop” that “engage Bechtel employees worldwide in small-group discussions and analysis of real-world ethics challenges they face in their jobs.” Higgins calls this ongoing approach to training a huge commitment of resources that “makes an impression” on everyone (Bechtel 2013).

Ease of Communication is Essential

Higgins also highlights the importance of making it easy for employees to communicate their concerns. Bechtel has an externally-managed ethics helpline (or hotline) and an ethics web line, both with 24-7 access. Employees can also report concerns and ask questions by email and regular mail. The company has also appointed ethics officers in all of its operating organizations and functions and has ethics contacts designated for many of its projects (DiPietro 2013).

Leadership Drives Ethics Performance

Five years ago retired Bechtel vice chairman Adrian Zaccaria spoke about Bechtel’s ethics culture at a meeting of the Ethics and Compliance Officers Association (Zaccaria 2009). He summarized his remarks by identifying six critical success factors for an ethical company. Those factors:

– Written policies and an established program

– Strong ethics and compliance organization

– Training

– Leadership

– Leadership

– Leadership

The scope of Bechtel’s approach and that of its Chief Ethics Officer’s responsibilities may be greater than it would be for small and medium-sized companies, but the essence holds true for all.

Ethical Advocate provides comprehensive ethics and compliance solutions, including ethics and compliance training and confidential and anonymous hotlines, meeting Sarbanes-Oxley (SOX), Federal Acquisition Regulation (FAR), and other regulatory and reporting needs. We would be happy to provide more information.


“Bechtel’s Approach to Ethics Training.” video clip, January 24, 2013.

DiPietro, Ben. “Q&A: Nancy Higgins, Chief Compliance Officer, Bechtel.” Risk & Compliance Journal, April 30, 2013.

Ethics Resource Center (ERC). “Nancy Higgins of Bechtel Tapped by Ethics Resource Center for 2014 Carol R. Marshall Award for Innovation in Corporate Ethics.” ERC press release, November 14, 2014.

Zaccaria, Adrian. “Ethics at all Cost.” Presentation to the Ethics and Compliance Officers Association, April 30, 2009.