Seldom found on lists of job duties and expectations, however, are statements about the need to plan for and manage the ethics and compliance-related aspects of transitions in organizational leadership. This is not true for ethics officials in the executive branch of the U.S. government.
Every four years, these officials must prepare themselves for either the possibility or the certainty of a change in administration. With a change in administration comes an almost 100% turnover in government agency heads and other appointed positions, and some amount of turnover in career management positions.
As outlined by the U.S. Office of Government Ethics (OGE) (2016), government ethics officers need to educate new agency leadership on their role in supporting a strong ethical culture and advise all incoming employees about ethics requirements—similar to what ethics officers everywhere do.
They must also “review public financial disclosure reports of incoming nominees, counsel outgoing employees on issues related to seeking and negotiating for employment outside of government, and implement strategies to manage the increased workload in the post-election period.” All of this needs to happen in a relatively short period; no small challenge. Meeting that challenge requires much advance preparation.
Experienced federal ethics officers and OGE staff understand the magnitude of everything that will need to be accomplished, they know the likely challenges, and they know they will need a combination of time, budget, and effective creativity to get it all done. OGE helps with advance planning by producing and disseminating a “transition readiness series” of distance learning and classroom learning events designed to train the more than 4,500 of them who will be dealing with the transition—and it starts offering them six months or more in advance of the need. (Some of the events can be viewed through the OGE Institute’s YouTube channel).
State and local government ethics officers also face the regular likelihood of transition in leadership roles. Ethics officers in other businesses and institutions are challenged with less regular but equally impactful leadership transitions and changes at other management levels as well. Less certain is the extent to which they have a plan for anticipating or responding to changes in their organizations’ leaders, managers, and board members.
To ensure your team does have a plan, consider taking a leaf from OGE’s playbook. Identify how and when newly promoted or hired leaders, managers, and board members ought to be brought up to speed on their ethics and compliance-related responsibilities and obligations. Identify all other ethics and compliance-related actions that needs to be done in response to leadership change—and when. Create a list of all potential pitfalls and challenges. Working with others in the organization, discuss (and document) alternatives for overcoming these pitfalls and challenges, and put a plan in place. Then, regularly refresh yourselves on the plan so that your team will be able to execute it in the face of organizational and leadership transition.
Ethical Advocate provides comprehensive ethics and compliance solutions, including ethics and compliance training and confidential and anonymous hotlines, to public and private companies and to educational and government institutions.
U.S. Office of Government Ethics. “OGE and Agency Ethics Officials Train for Post-Election Readiness,” Director’s Notes (web page), June 22, 2016.