According to the document, the question of whether organisational culture can be measured, especially its value-based component (integrity culture, ethics culture or compliance culture), has been examined by the academic community for many years, but there is still no consensus on a standardised approach.

At the same time, both governmental and non-governmental actors are increasingly recognising the importance of assessing these cultural aspects.

In this context, the authors of the Guide seek to address the question of whether and to what extent such measurements are possible and necessary in order to obtain additional and critically important information about the effectiveness of a company’s compliance and integrity management system.

Key concepts and benefits

According to the document, organisational culture is the set of shared values, beliefs and patterns of behaviour that determine the company’s “way of being”. It serves as an internal compass that guides employees in decision-making, interaction and the performance of their tasks. Different subcultures may coexist within one organisation, but a common value base helps align the actions of all employees with the company’s objectives.

Integrity culture goes beyond the simple observance of rules and reflects the company’s commitment to act in accordance with ethical principles, values and norms, even when this requires additional effort or time. Establishing and explaining values, rules and incentives is a necessary precondition for building such a culture. Integrity is reflected in the consistency of employees’ decisions and actions with the declared values. It includes not only anti-corruption measures but also respect for human rights, compliance with the law and the promotion of diversity, equality and inclusion.

A focus on integrity culture and its regular assessment ensures the company’s long-term resilience and high standards of responsible conduct. In particular, the authors single out the following benefits of a focus on integrity culture within a company:

1. Reduction of compliance risks - an appropriate integrity culture helps ensure that employees comply with requirements in situations where this cannot always be achieved through traditional compliance measures, and thus reduces the likelihood of breaches.
2. Effective protection of whistleblowers - the presence of an integrity culture creates an environment of trust and encourages internal reporting of misconduct.
3. Strengthening of brand and reputation - responsible behaviour increases the trust of customers, business partners and society and supports business sustainability.
4. Additional benefits for the company:

• attraction and retention of qualified specialists;
• growth of innovation in conditions of psychological safety;
• increased productivity, improved teamwork and, as a result, higher profitability;
• greater investment attractiveness, especially for ESG investors.

As regards the benefits of measuring integrity culture, the experts in the Guide highlight the following:

1. Compliance with normative requirements - regulators and international standard-setters (for example DOJ, ISO, ESRS) are increasingly requiring companies to demonstrate not only that a compliance system is in place, but also that corporate and compliance culture is measured on a regular basis, and culture assessment is becoming an obligatory element of reporting and audit.
2. Diagnosis of real commitment to values - measurement helps to determine the extent to which declared values correspond to the actual behaviour of employees and, in turn, makes it possible to identify “gaps” between stated values and real practice and to reduce reputational, legal and operational risks.
3. Testing the effectiveness of existing measures - assessment shows whether planned compliance initiatives have in fact been implemented, whether they function in practice and whether they achieve the desired effect. This helps adjust the strategy, address distrust of processes (for example, of the whistleblowing system) and correct mistaken negative perceptions.
4. Encouraging ethical leadership - the results of measurements give leaders concrete reference points for their development, help them to understand which behaviours and attitudes need improvement, what support managers require and where leadership problems are observed.
5. Launching a cycle of continuous improvement - culture measurement should be carried out regularly and be part of a process that allows systems to be adjusted on the basis of data and feedback, ensuring the relevance and resilience of integrity culture both under internal changes and under external pressures.

Preparing for assessment

Measuring culture begins with data collection. In particular, the company should determine:

• What data already exist in the company and may directly or indirectly reflect the state of its culture?
• What data are missing but could be collected?
• Who owns these data, who is or should be their data owner?
• What difficulties may arise in accessing such data, in collecting, compiling or interpreting them? What barriers may arise when they are shared?

At the same time, the following may be used for measurement:

• direct data that directly measure integrity culture (for example survey data);
• indirect data that do not measure culture directly but provide important signals (for example the number of cases where repressive measures are used against whistleblowers).

When starting a culture measurement project, the company is advised to proceed from the following assumptions:

• Data can be obtained:
  • from the compliance unit or anti-corruption unit (reporting system, investigations, training);
  • from the HR function (job satisfaction, staff turnover, engagement);
  • from public sources (for example reviews on external platforms).
• Some data will not exist in finished form and will have to be created specifically for the project.
• Some data are not yet accumulated by the company, but in the future they may prove important, and then the company will have to adapt its systems and add new data points.

Assessment tools

As tools for measuring integrity culture, the Guide proposes the following:

1. Surveys - the most widespread tool which, if properly designed, makes it possible to measure employees’ perceptions of integrity in the company, of fairness and equal treatment, the quality of leadership and trust in the whistleblowing system. In addition to employees, external stakeholders (clients, suppliers) may be invited to participate in surveys to obtain a broader picture. Surveys are conducted by the HR unit or the compliance function, but may use methodologies developed by external experts.

A separate section of the Guide is devoted to how to properly design and conduct a survey. In particular, the authors propose the following key recommendations:

• ensure technical anonymity;
• make the survey short and clear;
• use consistent response scales;
• include open-ended questions;
• test the survey before launch;
• explain the purpose of the survey and how the results will be used;
• set clear deadlines.

2. Interviews and focus groups - methods that allow a deeper understanding of employees’ day-to-day experience and the root causes of ethical issues. Such tools can be used to interpret survey results, but require the involvement of a “neutral” moderator and careful preparation. They are usually conducted jointly by HR and compliance specialists.
3. 360-degree evaluations (that is, evaluation of an employee with the participation of different stakeholders) - assume collecting feedback on a specific employee from supervisors, peers and subordinates and make it possible to form a comprehensive view of that person’s ethical behaviour. Although such data are individual, their aggregation at company level can provide additional indicators of culture. These assessments are usually carried out by the HR unit.
4. Exit interviews (interviews on leaving the company) - are usually conducted by HR specialists and can be a useful tool because employees leaving the company often speak more openly about problems, including ethical ones.
5. Open employee review websites - help verify whether the internal picture corresponds to reality. Research shows that such platforms can identify signs of a toxic culture.
6. Additional indicators - useful indirect metrics include: staff turnover; frequency of employee absences; performance appraisal results where they contain criteria of integrity-related behaviour; the extent to which the company’s values are reflected in management decisions; and how often leaders talk about the importance of honesty and adherence to norms. However, when evaluating such indicators, it is important to take into account the specific features of the company: for example, high absence rates may be due to the physical demands of the work, and high staff turnover may be related to low pay.

The authors of the document note that the most accurate assessment is achieved when different tools are used in combination.

It is also emphasised that companies are increasingly using tools based on artificial intelligence (AI). For example, some organisations develop their own tools that help to process large volumes of data, structure them, analyse at the same time the results of both direct and indirect indicators and interpret them in line with the company’s needs. Other companies create internal information resources (corporate portals, internal social platforms), including with AI integration, which are a valuable source of information on how employees perceive integrity culture and the organisation’s reputation. At the same time, simple AI tools implemented on such platforms make it possible to monitor discussions, identify issues, recurring themes and potential reputational threats, and more advanced solutions can analyse the emotional tone of messages and detect at an early stage indicators of breaches of ethical norms.

Challenges

The Guide also highlights gaps and challenges that companies face when measuring integrity culture, and areas where further research and development of practice are needed:

• Many companies confuse culture measurement with the assessment of compliance procedures, limiting themselves to analysing only formal elements such as the existence of codes, training, whistleblowing systems and so on, which does not reflect the actual state of culture.
• Key units (compliance, HR, legal, sustainability) often work in silos, and the absence of coordinated approaches prevents the formation of a holistic picture.
• There is no exhaustive set of indicators specifically designed to measure integrity culture, and new indicators need to be developed. Such indicators may, for example, assess the diversity of leadership, the number of dismissals due to unethical behaviour, absence rates and the impact of integrity incentive programmes.
• There is a lack of data on how assessment results are used and a lack of long-term observations, which makes it difficult to track trends and the impact of external factors.
• Although the tools presented are also suitable for small companies, their capacity is limited by available resources. In this regard, it would be useful to develop guidance on which tools are most effective for small and medium-sized enterprises.
• Companies operating in different countries face the fact that perceptions of integrity, honesty, transparency and leadership differ significantly, and cross-cultural differences complicate comparison of results between countries and require adaptation of methods.
• Artificial intelligence technologies open up new opportunities but require additional safeguards, including transparency of algorithms, possible errors and biases and compliance with legal requirements.
• Publication of data may improve reputation but at the same time increases the risk of criticism. Some companies are willing to share measurement results, while others fear legal consequences.
• Information from external actors (business partners) is almost never used in assessments, although it could complement internal evaluation.
• Although all interviewed companies are convinced that integrity has a positive impact on business, none of them has yet been able to measure this effect precisely.