Count me in the group that is both astonished and stunned by the corruption allegations made earlier today by the federal government against Illinois Governor Rod Blagojevich.  The blatant nature of the "pay to play" allegations is something rarely seen in politics. (Connecticut has obviously has its share of corruption cases.)  While the allegations involving the open Senate seat are juicy, there acourtesy morgue file "dollar" - NOT public domainre allegations that the Illinois Governor was trying to put pressure on the Tribune Company to stop running editorials against him, in exchange for some help selling Wrigley Field. 

But when a high-profile politician or surrogate calls one of your employees, does your company have a plan or policy in place to address this? 

Here are some issues for employers to consider:

1) Develop a Code of Ethics: Once confined to the largest companies, more and more companies have developed a Code of Ethics for their employees to follow. For an excellent example how a local Connecticut company handles the matter, you can check out United Technologies’ Code here.  It’s written in plain English and spells out what it will and won’t do (such as "offer or pay any bribe"). Even more importantly, it has designated individuals who can be contacted when such issues arise.

2) Designate and Train Individuals on How to Address Issues – It’s great to have a policy but if it is poorly implemented, it won’t be useful or effective. Find that core group of individuals with experience or expertise in this area and train them further on how to address issues such as bribery.

3) Communicate the Company’s Policies and Repeat Them – Policies work best when they are communicated to the employee population through various sources. Policies that merely "sit on the shelf" will not be incorporated into the company culture. Emphasize the company’s commitment to ethical behavior through e-mail, in-person meetings and newsletters. 

4) Enforce the Policies – Again, having a code of ethics that is routinely ignored will certainly not foster a culture of compliance. While each allegation of code violations should be treated differently, how the company reacts to the first few incidents will lay the groundwork for years to come.  It’ll be interesting to see how the Tribune company addresses the allegations that they were contacted.

5) Get Legal Advice – This oft-repeated phrase is important because each company may have different issues that it is likely to face. And when the company is confronted with an issue (such as a bribe suggestion), getting legal advice on how best to contact authorities and how to handle the matter internally may help keep the company out of harm’s way once an indictment comes down. 

And finally, I’ll leave you with this thought: December 9, 2008 is International Anti-Corruption Day as designated by the United Nations.  Obviously, there’s still a lot more work to be done in this area.  Considering steps like the above won’t prevent corruption from happening, but it can help minimize damage to the company if and when it does.