In addition to being the month for the annual performance evaluation, January is also the month when my company’s employees must complete a mandatory annual process called BCG Certification. This is a three part process where one must:
- Read the Business Conduct Guidelines (I guess I never realized these were available outside of IBM, but the hyperlink is provided in case any of my blog readers are having trouble falling asleep. Really compelling stuff.)
- Complete an online course on the BCG,
- Electronically certify that you have read, understand, and agree to the BCG.
You (and your manager) get electronic notifications to remind you if you haven’t completed the certification process in a particular time window. I got my notification yesterday, so decided to knock it off before the weekend. There is absolutely nothing wrong with reminding employees to act ethically in their business dealings but I suppose this also serves some legal purposes as well. After certifying, if an employee is fired because of failure to adhere to the BCG, it would be really difficult for that employee to take the Costanza Defense (Was that wrong?)
The online course features actors role playing various IBM employees working on some fictitious project and being confronted with various ethical dilemmas. Over the course of the 30 minute course, this project team manages to egregiously violate just about every major category of guidelines in the BCG. Interspersed with the riveting plot are questions about the ethical conduct of each of the actors. Questions like “Was IBM project lead Roberta acting in accordance with the BCG when she made a large donation to a charity run by the wife of the Customer Project Manager who will select the winning project bid?” Duh.
You used to be able to run quickly through the online course and skip the “lesson” pages and go straight to the questions that you have to answer to complete the course. But now the course software keeps track of how much time you spend on each page.
From year to year, the actual guidelines don’t change that much. They have been around in IBM for a long time. I have long thought that the entire efficiency of the whole process could be improved if HR would provide useful change bars on the document so one could just review the delta from last January. In recent years, some stuff about the dangers of social media has been added like the following from Section 5.4:
When you speak out on public issues or in a public forum, you do so as an individual, and you should not give the appearance of speaking or acting on IBM’s behalf. This is particularly important with the rise of social networking media. You must always be aware that such services are increasingly being monitored by clients, colleagues and regulators alike.
So let’s get this out of the way: This is a personal weblog. The opinions expressed here represent my own and not those of International Business Machines Corporation.
Despite the best intentions of IBM, there have been some relatively public and high-profile breaches of the BCG in recent years. Not surprising when you consider an employee population of over 400K. I keep waiting with baited breath to see if Section 5.2 “Inside Information and Insider Trading” eventually gets revised with a bullet like the following:
You should not disclose material inside information about the IBM Systems and Technology Group, Lenovo, and the entire IBM Supply Chain to any stock analyst (particularly if you are involved in an extramarital sexual relationship with said stock analyst). If you do so, you risk pissing away $65M USD in stock options and an opportunity to succeed Sam Palmisano as the next CEO of IBM. Oh, and you go to jail as one of the lynchpins in one of the biggest hedge fund scandals in history.
Maybe that will get added to next year’s revision – they can call it the Moffat Clause after the IBM Vice President who was a key player in the the Galleon hedge fund scandal. Wonder if old Bob blew through his BCG Certification in the 2000s?
By the way, in my research for this post, I came across an excellent article in CNNMoney on this scandal. As I read the article, I laughed out loud at some of the lame lines this Danielle Chiesi chick would lay on these power players to ensnare them into her little web:
She liked older men, and she enjoyed pushing their buttons. "I love the three S's," she would tell them. "Sex, stocks, and sports." Really? You mean she led with that weak sauce?
and then this gem…
It enriched some of them, it thrilled all of them, and it eventually ruined their careers. Trading business information, Chiesi would say, was "like an orgasm." Yeah, multivariate analysis, sales projections, mergers and acquisitions, and pivot tables are so hot.
