The Surgeon General Weighs In


By Adam Turteltaub

When it comes to guidance for compliance and ethics programs, we tend to look to the US Department of Justice criteria for evaluating compliance programs, the US Federal Sentencing Guidelines and an increasing number of non-US laws. Now, it seems, it is also wise to turn to the Surgeon General, and the newly-issued document “The U.S. Surgeon General’s Framework for Workplace Mental Health & Well-Being”.

It’s a well-timed framework. The pandemic has upended the work environment, and it’s not just that more people are working from home. As the report observes: “The pandemic also sparked a reckoning among many workers who no longer feel that sacrificing their health, family and communities for work is an acceptable trade-off.”

It also affected how businesses see things: “Organizations are also increasingly aware of another trade-off: when the mental health of works suffers so does workplace productivity, creativity, and retention.” And, as we all know, when retention suffers so too does corporate culture, which can increase ethics and compliance risk.

The framework contains “Five Essentials for Workplace Mental Health & Well-Being”: Protection from Harm, Connection & Community, Work-Life Harmony, Mattering at Work, and Opportunity for Growth. At the center of the framework is “Worker Voice and Equity”.

While the document is focused on creating a healthy work environment, it’s fascinating to see how much a healthy environment and an ethical, compliant culture have in common. As you read through it you will find much that echoes with what compliance teams have advocated:

  • “Mitigating harmful impacts in the work environment begins with a review by employers of all existing occupational health and safety legal requirements, and their own workplace policies and conditions to ensure standards and regular compliance.”
  • “Research suggests that five workplace attributes are most predictive of whether workers refer to their organization’s culture as ‘toxic’: disrespectful, non-inclusive, unethical, cutthroat, and abusive.”
  • “Organizational leaders should cultivate environments and cultures where connection is encouraged and workers of all backgrounds are included.”
  • “Having clear and consistent communication between workers and leaders is foundational in building trust.”

Sounds a lot like risk assessment, effective communication, enforcing standards and tone at the top,

Hopefully this will help employers better understand their workforce and create an environment where people both want to stay and expect to thrive.

Of course, no workplace will ever be stress-free, and wherever there are people there will be conflicts. Reducing those conflicts, though, and eliminating unnecessary stress can go a long way towards improving culture, not just for producing work but also for speaking up, raising issues, and ensuring that those issues are heard.

The report is also a good reminder to compliance teams that first and foremost we are in a people business. Our job is to positively affect human behavior, and to do our jobs well we have to understand human strengths and frailties.

As Dr. Aditi Nerurkar so eloquently explained in her talk at the Compliance & Ethics Institute, we have all been deeply affected by the trauma and changes of the last few years. We need to understand that and be gentle with ourselves.

To that I would add, we also need to respect the changes in each other, and remember that trust, respect and a healthy work environment are a good prescription for most everything we face.