Building a Meaningful Corporate Social Responsibility

In an earlier post, we talked about the importance of matching public support for the LGBTQ+ community with internal practices, policies, and employee training that support diversity and inclusion. This would additionally foster a workplace culture that complements an organization’s corporate social responsibility (CSR). 

The Value of Corporate Social Responsibility

After decades of CSR  initiatives and research, strong evidence supports its positive impact on both profitability and employee engagement

Studies show that more than half of consumers will pay extra for products from companies they believe are socially responsible, and 67% of employees prefer to work for socially responsible companies. 

Furthermore, and in a telling statistic for politicians, recent data indicate that 55% of consumers think brands are more important than governments in terms of creating social change. 

The question then is not, “Should my company have a CSR program or public statements about its corporate citizenship?” Rather, leaders should be asking, “How can my company make CSR distinctly meaningful and impactful for our employees and the community/nation/world where we do business?”

Nike & Google: When CSR efforts fall flat

81% of millennial consumers expect brands to make public statements about their corporate citizenship. However, these younger and social-media-savvy consumers are more and more adept at spotting when proudly promoted CSR efforts ring false.  When companies make public statements about their values or take a stance on a social issue, they risk criticism if their ethics record or internal culture does not reflect their external marketing. 


A recent AdAge magazine article summarizes this discrepancy brilliantly in a discussion of the recent “Believe in something, even if it means sacrificing everything” Nike campaign featuring Colin Kaepernick: “This campaign is great for Nike's business. However, by addressing the reasons why Kaepernick was kneeling in the first place – racist policing, unacceptably high rates of incarceration of African-Americans and economic exploitation, Nike would be even more successful.” 

The article notes that Nike has had issues with labor rights violations in its factories and internal complaints about discrimination and harassment of female employees. 


Similarly, Google regularly topped the list of companies with the best corporate responsibility reputations, yet has been mired in controversy over accusations that employees who advocate for diversity are subjected to harassment by fellow employees. 

Etsy & AirBnb: Walking the Talk

On the flip side, many companies benefit from creative, focused CSR initiatives perceived internally and publicly as authentic and aligned with the organization’s culture and value.  Both Etsy and Airbnb’s actions are directly connected to the company’s business model and focused on specific areas of impact rather than just making platitudes of support. 


For example, Etsy’s guiding principles include, “We embrace differences” and “We lead with optimism.”

It matches these values, in part, through its Advocacy programs which focus directly on issues that impact their sellers including net neutrality


Conversely, Airbnb reports, “Our new Community Commitment, stronger Nondiscrimination Policy and the development of a permanent team dedicated to fighting bias while encouraging diversity are just a few of the steps we’re taking to fight bias.” 

As part of this commitment,  Airbnb received attention in 2018 for allowing hosts to refuse to rent to white nationalists in Charlottesville, Virginia. The company also has a program called Open Homes which connects refugees with hosts willing to provide them with free short-term housing. 

Learning from Others

What can companies learn from Nike, Google, Etsy, and Airbnb?

Make sure your public, internal values, and employee training align. Positive change is possible, but only when employees have awareness of their own biases and emotions, know when and how to respond to negative behaviors, and fully appreciate the benefits of a civil and respectful workplace that transcend an organization’s borders to serve its community—all of which can happen with investment in comprehensive training and other initiatives. 

Not only will you create better relationships with your customers and employees, your company’s reputation for having a positive social impact will be built on a solid foundation. 

Connecticut Harassment Training Requirements Greatly Expand Under New Law

“Your time is up, my time is now.” 


New Englanders likely recognize the above phrase, which is uttered repeatedly in the entrance music for WWE superstar and New England native John Cena. Ironically, with WWE often associated with misogynistic practices towards its female characters, the phrase takes on new meaning in Connecticut with the advent of a law passed in mid-June that greatly expands the requirements for employer harassment training in that state.


Gone are the days when only supervisors must be trained in mid and large organizations. Instead, Connecticut now will require nearly every employee working in that state to receive two-hours of training on the prevention of sexual harassment in the workplace. 


According to a law signed by Governor Ned Lamont on June 18, 2019 entitled the “Time’s Up” Act, employers with three or more employees will need to provide their entire workforce with sexual harassment training by October 1, 2020 (unless training was provided after October 1, 2018). For those employees hired by organizations with three or more employees after October 1, 2019, this training must be completed within the first six months of their employment. 


Employers with three or fewer employees still must provide training, although the requirements for those small organizations look much like the old law, which required two hours of training for supervisors only. Under the new law, very small employers will be exempt from training the entirety of the workforce, but still must have their supervisors trained by October 1, 2020 (or within six months of hire date if hired after October 1, 2019). 


In contrast to many of the other states that have enacted mandatory sexual harassment training in recent years, Connecticut does not require annual or bi-annual training. Instead, the state requires that employers re-train their employees once every ten years, which eases the burden somewhat, an especially important fact given the large amount of time that Connecticut is requiring all employers to invest in training sessions. 


Should employers choose not to train, the new law imposes monetary penalties including fines of up to $1,000, as well as the potential for attorney fees and punitive damages when a complainant comes forward to the Connecticut Human Rights Organization with an accusation that his or her employer is not following this new law. The latter could cause a cottage industry within the Connecticut plaintiffs’ bar wherein attorneys seek clients within those organizations that are either intentionally or unintentionally ignoring the training requirement. This of course could cause far greater pain for employers who are not in compliance than the $1,000 fine.


Syntrio is well equipped to help your workforce comply with the new Connecticut training law. We encourage you to contact us immediately to develop a program for compliance.

The Department of Justice’s Gift That Keeps on Giving – Part 3

Two prior blogs have addressed the recently updated 2019 Department of Justice Evaluation of Corporate Compliance Program criteria. Department prosecutors use these criteria to assess an organization’s commitment to implementing and operating a compliance program when an organization comes before the Department, principally facing prosecution.


Among the chief factors that these criteria focus on is an organization’s compliance training and communications. Since 1991, when the US Sentencing Commission established its own evaluation criteria, training and communications has been considered as an integral part of a successful compliance effort. The Department’s 2017 criteria continue this focus, and the 2019 updated Department criteria strengthens it. While these updates do not substantially change those important considerations regarding training and communication, they do enhance these considerations in some profound ways.


First, let’s return to the 2017 criteria. It focused on four principal components:

  1. Risk-based training
  2. Form, content and effectiveness of the training
  3. Communications about misconduct
  4. Availability of guidance


Risk-Based Training

According to the DOJ, it’s important that training relate to employees’ jobs; to this end, an organization should take steps to determine which training should be delivered to which employees, rather than simply deliver general compliance training to all employees. More specifically, an organization should determine for employees that engage in high-risk activities or handle certain control functions which training they should receive and that is tailored specifically to their job functions. This provides a means to focus limited training resources to better prevent or detect compliance problems. The 2019 guidance adds to this the importance of supervisory training—specifically whether supervisors receive different or supplementary training specific to their oversight roles. This supports the 2019 criteria’s broader focus on the role of managers, their duties to both prevent and detect compliance problems and the greater risk they can present if they engage in misconduct.


Training Form, Content and Effectiveness

The 2017 criteria asked about whether training is provided in a form and language appropriate to its audience, and whether the organization measures the training’s effectiveness. This second criterion is even more important in the 2019 guidance due to its increased focus on whether a compliance program works in practice. The 2019 criteria adds four more factors:

  • What’s an organization’s rationale for its decision to use online, in-person on both formats of training? In other words, has the organization actively considered whether the training approach it chooses will demonstrate effectiveness?
  • Does the training address the organization’s lessons learned from prior compliance incidents? This, of course, assumes that an organization periodically assesses its risks due to past problems in order to fold it into training.
  • Does the organization test learners on what they learn to determine whether the training is effective?
  • What steps does the organization take when employees fail part or all of this testing? (Surprisingly, it appears some organizations fail to follow up on testing failures!)


With these updates to 2019 criteria, the DOJ signals that it expects organizations to give real consideration to the training that it implements—not just assume any training configuration suffices. It also indicates specific steps the organization can take to holistically demonstrate that the training will matter to what employees learn and what they do.


Communication About Misconduct

Outside (or perhaps as part of) training, the DOJ wants to see that leadership communicates about its attitude regarding misconduct—in other words, that leadership will take steps to discipline transgressors. To this point, an important factor is how the organization communicates when an employee is terminated, or otherwise disciplined (added to the 2019 criteria), for failing to comply with the organization’s standards. For those organizations concerned about a lawsuit for communicating about an employee’s termination, these criteria suggest that such communications be anonymized so the lesson can still be conveyed while the organization avoid running afoul of privacy concerns.


Availability of Guidance

Finally, the fourth criteria remains the same in the 2019 update: What resources does the organization provide to employees to support compliance policies, and how does the organization assess whether employees know when to seek advice and whether they’re willing to do so? The DOJ still wants organizations to actively and purposefully provide their employees with guidance regarding compliance risks and demonstrate they know whether employees are comfortable using this guidance.


Additional Expectations

The 2019 criteria emphasize that an organization’s training include its directors, officers, and where relevant, agents and business partners, in addition to its employees. They also reinforce the importance that training be tailored to this audience’s size, sophistication and subject matter expertise, such as through training on case studies or real-life scenarios and providing guidance on ways learners can obtain ethics advice regarding specific situations they face.


In Conclusion

These expectations raise the bar on the level of training that organizations should anticipate providing. An organization can benefit from responding to these criteria in many ways:

  • It will likely fare better if it should run into a legal action the DOJ oversees
  • We anticipate other regulators will adopt similar guidelines in evaluating organizations that violate their related regulations
  • These criteria, or similar ones, are likely to make their way into case law and the criteria judges use to decide verdicts and sentence organizations
  • This raises the bar on good business practices as more and more organizations respond to these criteria in beefing up their own programs


As shown, many reasons exist for an organization to carefully consider how to implement strong, effective compliance training. Still, many businesses will focus on the effort involved in delivering such training versus the chance of running into regulatory or legal problems. In taking such a short-sighted approach, these businesses miss the many benefits to their operations by avoiding compliance problems in the first place.

Syntrio’s Award-winning FlexCode Code of Conduct Training

We are very pleased to announce that Syntrio’s "FlexCode Code of Conduct Training" has been selected as a Runner-Up in the E-Learning category of the 2019 International E-Learning Awards, Business Division, given by the International E-Learning Association

What are the International E-Learning Awards?

The International E-Learning Awards are given each year for the best work in e-learning, mobile learning, and blended learning. All submissions are evaluated based on educational soundness, effectiveness, usability, and overall significance.

What is the International E-Learning Association (IELA)?

IELA was founded in 2007 and is a diverse organization made up of members from every continent who are e-learning professionals, researchers, and students coming together from the realms of business, industry, government, and academia.

What does this Award stand for?

The International E-Learning Awards recognize the best uses of technology to improve learning and job performance within companies or through individual professional development.

What is Syntrio’s FlexCode?

FlexCode is the next evolution in Code of Conduct training. Syntrio ethics and compliance training are designed to bring learners into realistic  situations, where they must immediately apply what they learn about a specific topic. Further, Syntrio’s customizable ethics and compliance solution favors practical and relevant information, unburdened by “legalese,” so employees absorb the benefits of ethical behavior, as well as explore how to respond when questionable situations arise.

Businesses can choose any combination of Core, Summary, and Ethical Snapshot modules to design course that suits their unique Code of Conduct training needs. To learn more visit 

If you want to learn more about the International E-Learning Association visit their website at 


Is Intolerance Boiling Under the Surface of your LGBTQ Diversity Initiative?

It is encouraging to see a large number of businesses showing enthusiasm for Pride month, when just a few years ago many companies were hesitant to publicly endorse their support for the LGBTQ community out of fear of things like “customer backlash” or “taking a stance.” Many businesses are thankfully no longer afraid to show support for a very important segment of the population, and are (at least outwardly) embracing sexual orientation and gender diversity in a variety of different ways. Such enthusiasm would make an observer think LGBTQ employees are happier at work than ever, but recent surveys and research into the subject indicate that may not be the case.


Recent Surveys Indicate LGBTQ Employees Still Subject to Intolerant Workplaces

According to a recent survey conducted in  by, at least 20% of the more than 600 people surveyed answered that their organization has a negative attitude toward the LGBTQ community (regardless of the organization’s public stance on the issue). Likewise, 56% of respondents answered that their organization should be doing more to recruit and retain members of the LGBTQ community to fill jobs where they work.


Similarly, a 2019 study conducted by revealed 43% of LGBTQ employees surveyed feel they cannot be truly “out” at work, and nearly half of those respondents (47%) felt they could lose their job if they revealed their sexuality or gender identity. The Glassdoor survey also revealed that 50% of LGBTQ employees surveyed had witnessed discrimination or harassment related to their own or another employee’s LGBTQ status.


Putting on a Happy Face is not Enough

Respondents to surveys indicate an overwhelming lack of desire to work for organizations that are intolerant of LGBTQ employees. Further, the disturbing findings in the and show that organizational perceptions of tolerance toward LGBTQ employees are out of touch with reality. For these reasons, it is clearly time for a change in the way organizations formulate and maintain their diversity and inclusion initiatives when it comes to LGBTQ employees.


All too many organizations are displaying rainbow icons on their social media accounts and donating money to LGBTQ initiatives, yet those same organizations are failing to support the entirety of their workforce. When companies put on a “happy face” to the public regarding LGBTQ issues, yet fail to support those members of that community working within their organization, the intolerance under the surface truly makes the “inclusion” portion of LGBTQ diversity and inclusion that much more painful to those that witness intolerance in the workplace.


The Law Should not be Your Guide (Unless it is Pro-LGBTQ)

Part of the reason organizations still feel hesitant to fully embrace LGBTQ diversity in their workplace is the law. It may surprise you depending on your geographic location, but 26 states still do not provide EEO protection to LGBTQ employees. Compounding this fact is the unsettled nature of federal law on LGBTQ discrimination and harassment.

Given the natural tendency of many compliance officers and HR departments to let the law dictate their policy, a surprising number of employers do not include LGBTQ protections in their policy. While the survey revealed 85% of responding organizations do have an anti-discrimination polciy in place for LGBTQ employees (regardless of jurisdictional law), this is still far higher than the 68% of employees who felt there was support and enforcement of that policy.


Employers need to embrace the concerns of their LGBTQ workforce and understand that the LGBTQ community is an exponentially growing segment of the workforce. The law in this area is changing, but more importantly, societal views toward those organizations that discriminate and/or are intolerant toward LGBTQ employees are extremely negative.


Syntrio takes pride in its support for the LGBTQ community and makes a point of emphasizing the importance of protecting this segment of the workforce (and all employees in general) in its courseware. If your organization is not doing all it can to support and protect LGBTQ employees, it is behind the curve and hopefully the eye-opening statistics discussed above are enough of a business reason to embrace your LGBTQ employees and ensure they feel happy and safe in their work environment