The British Software publisher Psygnosis introduced  its game “Lemmings” in 1991 for Amiga, Atari ST and PC. The player had the task to guide the cute little green figures from their starting to the end point. As the Lemmings had no self-initiative, they limited their actions on walking and climbing. To avoid that they fall into holes or other abysses, the player had to block the way, build bridges, include ladders and more. That way a level got cleared and similar started in a more complicated environment. The game sold 15 million copies so that different sequels had been published over the next years.

As Compliance Officer, an office full of Lemmings would present a red flag. As they follow everything their management tells them, they not dare to challenge the given tasks, even if they would violate laws and guidelines.

That self-confidence, but also the opposite helplessness are learned attributes confirmed an experiment by Martin Seligman and Steve Maier. They took dogs and separated them into three groups. The second and third groups got treated with electrical shocks. The dogs of group 2 had the possibility to stop the pain by pressing a button. The group 3 dogs had no possibility to stop this by their own behavior. For this they perceived the electrical shocks as randomly and inescapable.

In a second step both scientists changed the setup of the experiment. Now all dogs of the three groups had the possibility to escape the shocks by jumping over a low partition. As it was an easy task, the dogs from the first two groups had in general no problem with it. Only the participants from the last group showed a different behavior. As they perceived the pain as something inescapable, they not even tried to escape, but stayed in their place and gave their selves in to the pain.

Self-confidence or perceived helplessness are a result of classical conditioning. Not all groups or societies have the same importance for “standing up”. Similar to the presented dog experiment, also humans learn helplessness. According action and re-action, impunity is a treat to the implementation of a “stand up”-culture, independent if in society or a company. The Mexican UDLAP university published “The Global Impunity Index 2015”. This index gives an important overview of responses to corruption in 59 countries. Being transparent is the first step for a region, but corruption should not only be detected, but also adequately addressed. To ensure a proper corporate culture, it is imperative that potential violations receive an appropriate response, related to the wrongdoing and not to the employee’s rank within the organization. No one should be above the internal guidelines. If employees do not believe this, they will not perceive compliance as a partner.

To give the Lemmings a complete make-over and turn them into confident employees requires a high and honest effort to implement a change culture. Top Management is responsible to ensure that nobody is above the organization’s guidelines, the Ethics & Compliance department is the facilitator of this vision. Such a 180 degree change cannot be reached over night. It needs a longer period until all employees belief the situation that there are no more electric shocks. But the effort is worth it, as only an open corporate culture ensures compliance with values and guidelines, including usage of the whistleblower hotline, if required. For the last, employees need to trust that the company does not only not tolerates retaliation, but furthermore that an investigation wants to understand the situation and solve the potential problems:

Anticipated benefits of using the whistleblower-hotline > Anticipated costs of using the whistleblower-hotline