Finding ways for employees to feel comfortable speaking up when something isn’t right is challenging in the best of times. But with the backdrop of uncertainty from a bumpy economy and pending merger, the Activision Blizzard Ethics and Compliance team faces unprecedented headwinds. We’ll walk you through a few key steps you can take to foster a speak-up culture across your organization, even in a high-change business environment.
As Chief Ethics and Compliance Officer at Activision Blizzard, my priority is building a safe, inclusive workplace culture for all employees. But how do we do that when the ground is always shifting?
Step One: Find steady ground in policies and processes
Much like laying the foundation of a house, the bedrock of any culture is its policies and processes. At Activision, this meant auditing our existing documents and refreshing them with employee-first language full of real-world examples. Gone are the days of lawyer-speak: our focus was on building a Workplace Integrity Policy that our employees could see themselves in. It needed to feel current—and human. We applied the same approach to our Code of Conduct, which now includes scenarios and quotes from employees.
In addition to refreshing the language in policies, we also experimented with new ways of promoting policies to Activision employees. By releasing bite-sized narratives that revealed ethical dilemmas in Way2Play Stories and offering annotated PowerPoint guides and talking points for people leaders, we could start to bring our shared commitments to life.
Step Two: Create safe spaces for people to practice ethics
Once the foundation is in place, the job is to build virtual rooms of the house where employees can not only understand ethical decision making, but practice and role-play different scenarios. At Activision, we co-developed a live, interactive Workplace Integrity Training complete with common workplace situations. This gives all employees not only the chance to learn, but also the opportunity to rehearse bystander intervention in challenging moments fostering a speak-up culture.
Additionally, we empower our global group of ethics ambassadors (called Way2Play Heroes) to represent all parts of our business. They serve on the front lines of employees who might have concerns at work but aren’t yet sure what to do. To amplify the voices of all of our employees, these Way2Play Heroes champion speaking up at the grassroots level.
Along with equipping employees with practical insights about Workplace Integrity, we provide a clear list of reporting channels on our ASK List so employees know where they can raise issues. Those on the ASK List practice and gain additional skills to fulfill their roles and responsibilities when reports are made. Rather than have one singular reporting channel or escalation path, our preferred method is to share multiple ways of communicating concerns, including an anonymous hotline. By offering employees choice, they’re encouraged and empowered to select the path that makes them the most comfortable and confident in the process.
Step Three: Define a rock solid and transparent investigations process
Perhaps the most significant element of building a speak-up culture is the investigations process. Ensuring the right people, process, and technology are in place is table stakes; otherwise, employees lose faith in the system.
Over the course of a year, Activision’s Ethics and Compliance team has scaled from a few people to nearly thirty dedicated team members. Establishing the right resources and infrastructure to follow up on every elevated concern was paramount. By being as open as possible about how and when decisions are made, our Way2Play Ethics and Compliance team can follow through on our commitments to earn (and deepen) our employee community’s trust.
Step Four: Make speaking up a business imperative
In today’s competitive talent market, building a thriving workforce requires shared commitment across the business. To craft a speak-up culture, it can’t be solely a compliance, legal, or HR project. Real change comes from every member of the organization committing to speaking up and standing up for what’s right.
As part of a global company in throes of change, coordinated communication is key to enabling this speak-up culture. It also takes a shared commitment from the leaders who model day-to-day behaviors, and fully listening to people’s stories if we miss the mark.
The Heartbeat of the Organization
Your organization is likely experiencing its own version of uncertainty and state of change. We often see unethical behavior emerge during these inflection points—even when they’re positive ones. By fostering a speak-up culture, our goal is stay closer to the heartbeat of the organization, hear about the small issues before they escalate, and empower every player to be a part of creating a culture where everyone can do their best work together. We’re by no means perfect, but we’re committed to reinforcing a better and more ethical house. Brick by brick. 
Jennifer Brewer is Chief Ethics and Compliance Officer at gaming company Activision Blizzard. Anne Jacoby is CEO of Spring Street Solutions Co., a strategy consulting firm based in Los Angeles.