How Do You Measure Culture? Part I – Direct Inputs

Casual start up team brainstorming in co working space

By Kristy Grant-Hart CEO of Spark Compliance Consulting

The Merriam-Webster Dictionary defines “culture” as the set of shared attitudes, values, goals, and practices that characterizes an institution or organization. That’s a pretty heady idea. We know from regulatory expectations and personal experience that creating a culture of compliance is critical. But it can be tricky to get our hands around what that means and how to measure it.

The DOJ has Spoken

The Department of Justice’s (DOJ) Evaluation of Corporate Compliance Program guidance uses the word “culture” 13 times in 19 pages. When it comes to an expectation of measurement, they are very clear. Prosecutors are to ask, “How often and how does the company measure its culture of compliance?”


Although the DOJ expects companies to measure culture, it doesn’t give much insight into how they expect that to be done.

An industry group called Tapestry Networks created a five-step framework for board oversight of culture. Step four of this framework relates to measuring and monitoring culture. They give examples of direct and indirect ways to measure culture.

This is part one of a two-part series describing ways to evaluate, measure, and monitor culture. This part reviews direct inputs. These come from both the Tapestry Network’s examples, as well as those we see at Spark Compliance.

Direct Inputs

Direct inputs are just that – information that comes directly from the employees themselves. There are many ways to obtain this information. For instance…

  1. Ethical Culture Surveys

Ethical culture surveys are the most direct and in-depth way to obtain information about your culture. Many technology companies and consulting groups offer ethical culture surveys as a service. Some offer benchmarking to put responses in context. Others track year-on-year changes to provide analysis on trends at the companies.

These surveys can be expensive, so some companies perform their own using Teams polling software, Survey Monkey or other tools.

  1. Engagement Surveys

Many companies perform engagement surveys. Engagement has been linked to a positive culture and employee retention, so this information can give good insights into the corporate culture. Many companies include ethics and compliance-related questions in their engagement surveys, making these data sets a rich place to data mine.

  1. Focus Groups

A focus group uses a neutral monitor (frequently a person from outside the company) to ask questions of five to ten employees at a time about the corporate culture. Focus group reports don’t usually attribute names to quotes, so participants are more likely to provide honest feedback.  They are a great way to gain insight into microcultures that exist in different regions and business units. Having a neutral moderator encourages candor.

  1. Round Tables

Round table meetings are similar to focus groups, but they are typically run by someone in the compliance department who asks the questions and takes down the feedback. Round tables sometimes have nominated speakers, with the audience chiming in as they wish.

  1. Exit Interviews

Exit interviews are a terrific source of information. People who are leaving are often prone to tell the truth because the fear of retaliation dissipates or disappears.

Some of Spark Compliance’s clients only interview people who are leaving voluntarily. This is a mistake, because frequently the angry employees are the ones who tell the truth most passionately if the culture or managers are bad.

  1. Site Visits

There’s nothing like being on-site to get a feeling for the culture of the location. The way managers speak to employees and each other can give great information. Are people fearful? Open? Closed? How do they interact? Gathering this information for several sites will give you a picture of the culture outside headquarters.

  1. Interviews

Interviews can be used to get a cross-sectional view of culture. Many companies interview workers at various business units and locations to get a sense of how they feel about the culture and their roles. If there are major differences, this can be valuable information.

  1. Pulse Surveys

Pulse surveys are short, easy-to-answer surveys put out to the employee population to get an immediate read on culture and ethics. Many companies use these in lieu of larger ethical culture surveys which take more time to complete. Others use them to keep a “pulse” on the culture throughout the year between ethical culture surveys.

Putting it Together

The best way to measure culture is to take a multi-faceted approach. By using two or more direct inputs, you will get a more nuanced understanding of the company’s culture and commitment to compliance. By adding indirect inputs, you’ll have a much richer understanding of the culture than with direct inputs alone.

Part two of this series explores indirect ways of measuring and monitoring culture. It will be published shortly. In the meantime, if you haven’t utilized focus groups, an ethical cultural survey, or any of the other direct inputs, start planning now. Once you have base data, you can compare it year-on-year, giving you a great answer to the question, “How often and how does the company measure its culture of compliance?”

Read Part II here