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How Do We Mitigate Ethical Risk?

by Victoria McKenney, Deputy General Counsel - Reg and Compl & Dep Chief Compl Officer


 It seems every year a new corporate scandal rocks everyone from Wall Street to Main Street. For companies, the repercussions can be severe: enforcement actions, lawsuits, civil and/or criminal penalties, and reputational damage. While no organization is immune, is U. S. Steel at risk? 

A few years back, Harvard Business Review published an article written by Alison Taylor titled, “5 Signs Your Organization Might Be Headed for an Ethics Scandal.” Consulting with investigators, regulatory monitors, and academic experts, Taylor identified these five factors that,  when one or more are present, could indicate that a company is heading for an ethics scandal:  (1) decision-making driven by urgency and fear, (2) isolation of groups, (3) lack of accountability, (4) a culture that celebrates success by any means necessary, and (5) language and jokes that cover up wrongdoing.  

And again, while no organization is immune to these factors, U. S. Steel’s culture is decidedly different.  We have an excellent and strong tone at the top, set forth by our CEO, Dave Burritt, and echoed by the senior leadership team that sets the stage for everything we do. We stress that our work is guided by our S.T.E.E.L. Principles and any significant business decision is approved only after a thorough and analytical decision-making review with input from many different stakeholders.  In accordance with our “Excellence and Accountability” S.T.E.E.L. Principle, we expect every employee to be held accountable for their actions. We emphasize doing business the right way and that no success is worthwhile if our “Safety First” or other S.T.E.E.L. Principles are compromised.  We are transparent about our decisions, our strategy, and our safety and environmental goals.  We work in cross-functional teams and encourage diverse of points of view. And in fact, the work we do has earned our company a place as one of the 2022 World’s Most Ethical Companies by Ethisphere, a global leader in defining and advancing the standards of ethical business practices.

And even with all that, there’s still more we can do to mitigate ethical risk.  As Taylor notes, each of us can make sure that we are having frequent conversations with our team members.  Managers should check in often with their employees, regardless of location, to make sure they feel connected to our company, our strategy, and our core values.  We should encourage each other to ask questions and report any concerns  to supervisors, Human Resources, Corporate Security, or the myriad of other resources available, including our hotline.  .  We should solicit and offer feedback, in assessments, surveys, and other tools that we utilize.  As Taylor notes, these types of conversations and feedback mechanisms can help us better understand the risks inside our organization and take additional steps to mitigate them.

Achieving Best for All® certainly requires the best from all of us, and that’s a culture and environment rooted in our S.T.E.E.L. Principles.


About the author

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Victoria McKenney is Deputy General Counsel, Regulatory & Compliance and Deputy Chief Compliance Officer.