The only way is ethics: how Wellcome is developing an integrity culture

That’s even more true in a philanthropic, high-profile organisation like Wellcome which is often held to even higher levels of accountability. Fraser Simpson, Wellcome’s associate general counsel for ethics, governance & compliance, explains to Neil Pearson, Mills & Reeve’s head of ESG and social value, how he has been working towards catalysing an integrity culture at the charitable foundation.

The law sets the minimum standard that everybody must adhere to. Ethics goes beyond that. How do you go about setting a higher goal for the Wellcome Trust?

“To analogise with the high jump, legal compliance is simply clearing the bar. To have an ethical approach, we need to focus our energies on raising the bar.

“What that looks like is going to vary in every organisation so the first step is to identify critical risks. For some organisations that’s clear. If you’re an NGO working with children, for example, you need to push the ethical bar around safeguarding. In other areas, it can be complex.

“One issue at Wellcome we’re very aware of is bullying and harassment within research and academia. As a funder and an actor within that space, we certainly don’t want to perpetuate that problem, and moreover we need to take a clear positive stance against such behaviours, using our spheres of influence and control, and also demonstrably walking the walk ourselves.

“Once you know your key risks, put in place a framework to ensure a consistent and thorough approach. Every time we review a risk area, we assess the risk; design and develop the policy environment and create accessible tools to enable the first line to meet the challenges; communicate in an engaging way; and monitor, evaluate and report upwards and outwards.”

How do you build ethical thinking into the everyday DNA of an organisation?

“It is a cultural issue rather than one simply of procedure or process – those are critical but in themselves insufficient.

“We started by focusing on our internal accountability structures, in particular by proactively encouraging staff to talk about concerns by building a “speak up” mechanism. Staff can report their concerns of breaches of policy or the law with their line manager, with our ethics, governance and compliance team or anonymously through a third-party reporting line. We also provide a confidential advice line for all staff through our partnership with Protect to help staff who need support in how to speak up.

“Central to this is driving psychological safety and trust for staff to raise their concerns. And it’s working – there’s been an increase in people raising concerns anonymously, and importantly we’ve also noticed a marked increase in people just talking to us informally. This shows we’re making progress in helping staff feel safe and confident they will be listened to, and their concerns acted on. It takes time, empathy, communication and reinforcement to build trust, but we’re seeing signs of real progress.”

How do you engage staff in the issues and make policies “living documents”?

“What we’re trying to avoid is creating a library of tedious, impenetrable 40-page policies. One of the approaches we take is really simple – we add a summary at the top of each policy with the 10 most vital takeaways for readers. We also try to keep documents user focussed – short, in a common format and in straightforward, inclusive language. We’re also currently exploring how we can use visual design to make policies more readable.

“But the real difference comes from not just stopping at creating the policy! How do you unpack the most important ones? For us, that’s around creating momentum by offering user-focussed, engaging training in ways that people find interesting and relevant, and through regular communication with visible senior leaders, as well as a diverse range of influencers across the organisation.

“Culture isn’t homogenous across the organisation. Certainly, when you look at Wellcome, the grant-making team, the investments team and Wellcome Collection team are all very diverse in terms of working style and environment. And on a practical level we’re not even all sitting behind a computer with access to the organisation’s intranet. One type of communication won’t work for everybody so we really have to try to understand user needs and be proactive in how we might need to adapt communications.

“One of the approaches we’ve taken, with a title which is a bit tongue-in-cheek, is a series of lunchtime talks with outside experts called ‘The Only Way Is Ethics’. I strongly suspect that if I ran a session about our modern slavery statement, not many staff would turn up. But, as part of this series, our partners Unseen UK came to talk about modern slavery globally and nationally. Rather than just tell people about our own policy and statement, we explored the issues it’s designed to combat – giving it context and relevance. Suddenly that is a much more enriching conversation where our people can see how it relates to their own lives and work.

“In my previous role working for an international NGO, we used the term “communities of enthusiasm” and creating these really can be a way of driving progress and sparking conversations.”

Would you change anything looking back at where you started to where you are today?

“I’d communicate more. No matter how much you communicate what you’re trying to do and the rationale of why, it’s important to keep repeating the messages so they stick. It’s easy to sell investment in ethics, governance and compliance off the back of a crisis – but it is much harder to do so without an immediately burning platform!

“I’d also say, don’t underestimate the length of time cultural change will take so you can manage expectations accordingly. This has to be an incremental journey. It’s not possible to leap to a perfect solution.

“And I would keep collaborating with others – knowledge sharing very proactively with experts, networks and peer organisations in similar fields, enthusiastically trying to achieve similar changes.”

How can organisations create an integrity culture?

“For me the starting principle is always ‘are we confident that staff feel safe to tell us when things go wrong or could be better?’ That doesn’t have to involve expensive technology solutions, it’s based around talking, actively listening and building trust with and between staff.

“Then it’s about identifying key risks that are central to your organisation’s DNA – those areas where you want to raise the bar and channel energy. Then take it incrementally from there.

“It’s such a fascinating sphere to work in because what we’re doing is strategically responding to society as it changes and so the challenges will continue to come.”

This article first appeared on The Lawyer on 2 December 2021.