The purpose of this paper is to report findings from interviews with ethical advisors (or those in equivalent positions) at five major aerospace companies. Using these interviews, I intended to explore what means were available for employees to voice ethical concerns that may arise in the workplace. To maintain a core of similarity across the corporations, I mailed the same scenario to each advisor. The scenario, which is included in this study, described a hypothetical situation in which an employee is concerned with the way the corporation is handling a particular contract.
The scenario was intended to be intricate but incomplete. Depending on its interpretation, the problem could reflect a major safety issue, a minor operation issue, or a trivial problem. I chose this scenario because the problems it poses are similar to those that arose when a planned system for Boeing/Sikorsky's Comanche helicopter was scrapped, due to the fact that exhaustively testing the system was too difficult. I personally believe that someday, if such a system is finally developed, even then it will be impossible to fully test it. In addition, because I can easily see myself encountering some of the subtle issues presented in the scenario, I wanted to examine various large aerospace companies handle such concerns. Therefore, I felt the best approach would be to use the scenario as a point of departure for examining and comparing many aspects of the companies' built-in systems for handling ethical concerns.
Unfortunately, this approach led to some problems in the interviews. The scenario was a little too technical and a little too intricate. Some of the interviewees did not want to treat it as anything more than a managerial or an organizational problem. In general, the interviewees were not as flexible in working within or around the scenario as I had anticipated. For the most part, they seemed to have definite ideas about the way their company worked, and preconceived notions about how the scenario did or did not fit that image. In hindsight, it would have been better to have a shorter, more well-defined problem rather than trying to explore so many avenues at once. Furthermore, it would have helped to take a more realistic approach, specifically concerning the position of the (relatively) new employee and the contract in question.
For Company A, I interviewed Mr. V., who has been in his position for over two years. His initial reaction to my scenario was that Company A would not sign such a contract in the first place, but that any "holes" in the customer's requests would be settled before such a situation got so far. Nonetheless, he was willing to believe that it could happen, and felt that, for the most part, it was plausible.
He indicated that if the employee is still unsatisfied after talking to his supervisor, he has three possible courses of action. One course of action is to go to the next higher level of management (he acknowledged that this is often difficult); another is to find a peer who agrees with you and re-approach your supervisor; and the last is to call the office of business practices. If the hotline is used, Mr. V would outline the employee's concerns in writing, and launch an independent review of the problem. Most often, this means that the independent review team will go to the next level of management to discuss the situation. If the team feels that the charges are unfounded, the caller will be contacted and the findings will be discussed so that the caller understands why nothing is to be done. At this point, if the caller is still unsatisfied, Mr. V indicated that he can call a whistleblower hotline number.
If, however, the team agrees that a problem exists, the team will bring this to the attention of the highest level of management involved in the project, and give recommendations as to how to resolve the situation. The management must take action unless they can prove to the investigating committee that there really isn't a problem. If disciplinary action is taken, the appropriate section of Human Relations is told to watch for any possible instances of retaliation by those who have been disciplined. Furthermore, if the employee feels that retaliation of some kind has taken place, he is instructed to call the hotline number and an investigation into the matter will ensue immediately. This sort of occurrence will not be tolerated, and any retaliation with substantive proof will result in immediate firing of the offender.
An interesting system Company A has in place are local ethics advisors, who may be consulted for advice on certain actions. For example, if someone is unsure as to company policy, or whether or not they can accept a gift from a customer, they can call an ethics advisor to get advice on the situation before a problem occurs. The corporate-wide hotline system is in place to treat the situation after a problem has arisen, although Mr. V also gets many advice-oriented calls, and many calls where the call is not an ethical concern, which he simply refers to the right person to talk to. Furthermore, Company A does have an ethics training program, whereby employees and managers are constantly reminded of the integrity of the company, and of the conscientiousness required to prevent unethical practices.
Company A goes to great measures to reduce the reluctance to call the hotline and to ensure privacy. One of these is the availability of two phone numbers: one on the company phone system, and an 800 number that may be used outside of work if the one is hesitant to call from one's office. The phone in the advisor's office does not display any incoming phone numbers; the door to the office is automatic-closing and soundproof to prevent any interruption; and no calls are ever recorded. The hotline will accept calls from anyone, including those who aren't employees or customers of Company A, and they investigate any and every concern regardless of who made it or how serious it is. To ensure that Mr. V has the necessary authority to conduct any investigation, he is only two steps away from the CEO. Furthermore, his position is not a career-builder; only people who have been with the company a long time and will retire soon are elected to this position. This practice helps to ensure that the advisor is unbiased and neutral. Most of these measures were not taken at other companies.
Back to Top
At Company B, each organization has an ethics administrator. Administrators handle employee concerns within their respective groups, and there is also a corporate-wide ethics hotline intended for concerns with farther reaching implications. I spoke to Mr. W, who is part of this hotline system. While he also felt that the scenario was plausible, he felt that it probably wouldn't occur at Company B either, because it describes a fixed-cost contract where only a variable-cost contract would be accepted (due to the fact that it involves complex software work). He pointed out that the A-12 cancellation was directly due to situations similar to my scenario, and indicated that if the contractor did sign on to such a contract, the customer was to blame for any problems in their requirements; if the requirements are met, then the company has done its job. Furthermore, Company B has "design review boards," meetings that discuss the job and the contract. Mr. W felt that problems like the ones arising in my scenario could be ironed out at such a meeting.
If, however, such a problem did arise, and immediate management was not responsive to the employee, the next appropriate course of action is to call Company B's hotline. Although any and all complaints are investigated, all are not necessarily put in writing. If a written complaint is needed, the caller is asked to document his concerns. The system is highly placed within the company to ensure that ethics advisors have the authority and the power to see that an investigation takes place. When a call is received, it is used as a "tip" first - that is, as a point where an investigation should start. The ethics administrators attempt to find collaborative data elsewhere before using any of the caller's information. Concerns are investigated, and if a problem has substance, then recommendations are formed by the investigating group and are reviewed by the appropriate management. Then, they implement proper disciplinary action and take measures to ensure that no repercussions fall upon the caller as a result of the complaint. There have been no reports of any retribution by employees who have called the hotline; it is clear in the company's policy that such action is not allowed, and Mr. W felt that this was a strong deterrent to this potential problem.
Some items of interest: Mr. W disagreed vehemently with the idea that there is a reluctance to call the hotline, supporting his statement by saying that 65% of the calls received are for advice and 35% are to report something. He also said that all the calls amount to 4.2% of Company B's population. He also mentioned that 12% of the reports result in corrective action. Furthermore, he said that Company B has recently implemented ethics training classes for many of their employees; in these classes they are instructed to call the hotline should their immediate management be unable to satisfy their concerns.
He indicated that the DII caused Company B to move to implement a disciplinary program that was directed towards white-collar and management employees, whereas most of the previous policies were directed towards hourly employees only. He clearly did not advocate whistleblowing, indicating that Company B has admitted problems to their customers and the government when they surface. He feels that the company can work out a better resolution with the contractor directly than by involving a separate government agency and lots of press. Apparently he preferred this approach to minimize the bad publicity often associated when an employee decides to blow the whistle on his company.
At Company C, I spoke to Mr. X. He runs the Company C hotline, the only phone number available to employees who want help with issues or concerns. He felt that the scenario primarily presented an organizational problem, indicating that the real solution is to go back to the customer and discuss the situation. To this end, Company C conducts Program Reviews with the customer. In a program review, many different people on the project meet to discuss progress and concerns. Mr. X felt that a concerned employee could use the program review as a forum in which to raise concerns to the customer directly, in front of the people who are most informed about the project. Furthermore, there is an Engineering Manager and Program Manager for every contract in which Company C participates. Problems may be taken to these people for resolution, as they oversee the projects and have a good overall picture of the endeavor. Mr. X stated that because concerns are often due to misinformation or lack of information, most problems can be resolved by talking with these directors.
If neither approach is successful, one could go up a level in management. For example, the employee could indicate to his boss that he is still concerned, and request a joint meeting with his boss and his boss's supervisor. In most instances, this is a way of moving up the ladder without "going over heads." He indicated that, as a rule of thumb, an employee with concerns should ask himself: "Can I satisfy my subordinates with the information I have gained from my inquiries?" If he can, then it is likely that his job done, especially if he has already gone up two levels of management. This interesting statement indicates that, in Mr. X's mind, low-level managers are unlikely encounter ethical problems themselves. He seems to think that most of such concerns will be felt and raised by low-level employees and not by management. His statement may have been prompted by a limited understanding of the scenario.
If none of these channels provides satisfaction for the employee, then there is the Company C hotline, and the person who will probably answer the phone is Mr. X. He will gather facts from the caller, and will make an independent inquiry to the program manager and peer staff involved. If the concern is a safety issue, then the Safety Engineering group will also be contacted. He felt that employees should document their concerns as a matter of course, especially if they are concerns that are brought to his attention by a subordinate. In fact, the program manager will most likely expect early and complete documentation of concerns about the situation.
In the case of a safety issue, all employees are required to write down any and all concerns that arise. Furthermore, safety issues should immediately be reported to one's supervisor, who will presumably take immediate action.
The advisors for the hotline are highly placed. Mr. X indicated that he could take issues all the way to the company's president if necessary. His job is to see that management is aware of the concern and takes any action necessary to resolve the problem. He does not suggest what should be done about concerns; rather, he brings the concerns to the attention of the proper people. But, if management disagrees with the accusations, they must be able to justify their actions and statements well enough to satisfy him. He is more likely to organize and initiate investigations by others than to investigate a complaint himself.
If the company is not receptive to the issue as it is raised through one or more of these channels, the employee can call the government's whistleblowing hotline. If the company's resources have been used extensively and thoroughly and the employee is still not satisfied, it is acceptable to blow the whistle. Such a course of action does not solve the problem quickly, and it is not recommended, but it is every citizen's right to have the option of doing so. In order to justify calling it, however, there must be a complete breakdown of all systems internal to Company C. He emphasized that the most effective methods to solving any problems that arise are almost always the most direct approaches.
Unlike the other companies, Company C posts the company's hotline number on most of the corporate telephones. For Company C, DII brought about the hotline, a code of ethics, and ethics training classes. As far as retaliation is concerned, such action is not allowed, and Mr. X looks for ways to protect the caller. Company C has clear warnings that such action will result in discipline, and if the fear of retaliation is high, it is common to reassign (physically relocate) one of the two parties in order to discourage that from happening. In certain circumstances, it may be necessary to reassign the caller rather than the "offenders." Although it is very important to protect the individual, Mr. X also stressed that it is also extremely difficult to determine what retaliation is; subtle behavioral changes are often difficult to pinpoint as indications of revenge.
I spoke with Mr. Y, who is the Company ethical advisor for Company D. (The Corporate advisor, Mr. Q, was out of town.) Above him is the Vice President of Human Relations, who is immediately below the Company President; thus, Mr. Y is not organizationally linked to Mr. Q, although they often work together. Each company within Company D has its own hotline for ethics concerns. In fact, Mr. Q serves largely as a different route for employees to take if they prefer to call a "corporate level" number rather than a "company level" number. However, most of the calls he receives that pertain to his company are referrals. In fact, most calls to the Corporate line are referred to the appropriate Company hotline employees, although a few are investigated by Mr. Q directly.
Mr. Y said that management has been taught not to give the response shown in the scenario, but if that does happen, the next step is to go to Human Resources. If their help is unsatisfactory, then the employee can call the hotline. For the most part, Mr. Y serves as an ombudsman, explaining who to contact or who is most likely to know what is going on and who is best equipped to handle a possible problem. In extreme circumstances (such as gross misconduct or criminal allegations), he calls on Investigation Services, a branch of Company D's security. In this case, they handle almost all of the investigation and any resulting disciplinary action.
He indicated that, unfortunately, a large percentage of the 8-10 calls per week are disgruntled employees. Most of the remaining calls are not appropriate for him to handle, and he refers them to the proper people. Of the remainder, every case is investigated by some group. He documents the concerns reported by the caller when the call is placed, and the investigating group documents their findings at the conclusion of their investigation. Mr. Y then calls the employee and reports their findings, and what, if any, action is to be taken regarding the original complaint.
Company policy is very clear on the issue of retaliation; it is illegal. Demonstrable retribution results in disciplinary action, but fortunately this is very rare, probably due to the clear company rules. For Company D, the DII brought about a focusing of the method for filing a complaint, and the institution of the hotline to expand the company's ability to handle ethical issues.
For Company E, I interviewed Mr. Z. He does not run the hotline at Company E, but overseeing it is one of his several responsibilities. He stated that the scenario was unrealistic for several reasons. First, the scenario depicted a fixed price contract for an order that could only realistically be done on a variable-price basis. Furthermore, at Company E, he said that there is a better management structure for such projects, and the team leader would have been more experienced. Lastly, he felt that the prominent issue of the scenario was a business or organizational issue and not an ethical issue. He pointed out that there are always unknowns in contracts.
First of all, for such a situation, he felt that any concerns could be brought up in one of the regular staff meetings where separate groups get together and discuss the issues and assumptions of the contract, as well as any problems that arise. For a "normal" ethical concern, the first step is to one's immediate supervisor, just as in the scenario. Mr. Z said employees should carry their concerns as far as they can with their supervisor, but if results are not forthcoming, then they have two options. The first is to go to the next level of management. He suggested that an employee may do this by confronting the manager with a statement like: "I'm not satisfied; I'd like to talk to your supervisor." The other option is to call the ombudsman. As ombudsmen are located at the corporate level, they may have a more objective outlook on the situation. Calls to this ombudsman may be completely anonymous if the caller so desires, but Mr. Z recommends calling the number only after the employee has exhausted management possibilities for resolving the problem. In fact, he feels that most of complaints are due to a lack of information, and learning more about the situation usually resolves the concerns.
When an issue is raised, the ombudsman investigates the problem, usually by talking to immediate and higher levels of management, and by examining the contract to which the concern is related. Documentation of the employee's concerns is not normal procedure unless the problem is serious and implies widespread consequences. The ombudsman takes care not to incriminate the employee in this process. If a problem is found, the general manager associated with that department is told to fix the problem found by the ombudsman's staff. Contact with the employee who expressed concern is maintained throughout this process.
Company E is sensitive to the need for fair treatment of those who have reported anyone or anything to the hotline number; there are rules and guidelines in place to prevent retaliation as a result of filing a report.
The hotline was established as a result of the DII, when government contractors and the defense industry in particular was attracting lots of attention because of the overcharging on contracts. Although he does not know for sure, he estimates that the hotline receives 20-30 calls a month.
Return to A Comparison of Ethical Concern Channels in Aerospace