Integrity Program: how we help Wilders make decisions based on our ethical principles

Oct 13, 2020 8 MIN READ Melissa Cruz Cossetti

Sabrina Faleiro shares an inside look at how the Wildlife’s Integrity Program was created and why it’s so important for us

Sabrina Faleiro had been at Wildlife for eight months when she launched one of the biggest projects of her career. Sabrina is an experienced lawyer in the area of compliance, and now her name is directly connected to Wildlife’s Integrity Program, a joint effort of three teams Legal, Communication and Human Resources – that came to be in the course of five months.

“I have always looked at the legal department  as a business partner and the integrity area reflects a lot of this connection, because in addition to applying the law, you contribute positively to an ethical work environment and ensure the well-being of all employees,” says Sabrina.

The challenges in creating the Integrity Program were huge, but the gains are even greater. In addition to establishing processes for maintaining relationships within the company, ensuring a safe working environment and talent retention, Sabrina says that an integrity program is capable of bringing benefits beyond the company limits.

“Apart from having an important role to mitigate possible risks, reduce turnover and avoid behaviours contrary to an ethical and respectful environment, this program also shows our investors how we’re committed to nurturing a safe and healthy environment. In the end, the goal is to make the company grow in a healthy way without leaving aside the highest standards of ethics and integrity,” she says.

Sabrina is not talking about a series of plastered rules and standard professional conduct manuals, though. The project, after all, was set in the “Wildlife way” of doing things, supported by communication strategies aimed at a young technology company in constant growth.

Read the full interview and learn how Wildlife planned its integrity project, using easy and lightweight communication, to give Wilders the tools they need to maintain a healthy and ethical working environment.

Sabrina, what is the Integrity Program exactly?
The program was launched to reinforce our principles and values and to create a safe space where people could report any situation contrary to our code of conduct and policies. The program has five pillars and all of our actions are based on them:

1. Talk to Us, a secure channel managed by an independent vendor where Wilders or third parties can report (in a totally anonymous way, if they prefer) any kind of misconduct that goes against our values, Code of Ethical Conduct and policies;
2. The commitment of our leadership, which supports and fosters our initiatives;
3. Clear policies, with objective and straightforward contents;
4. A more technical pillar, which involves an analysis of the company’s risk profile and guarantees that we’re complying with all our legislation; and
5. Constant training and communication to reinforce our Program. As much as people have access to the company’s policies, they need to be trained and we need to be close to them constantly. Launching this project during the pandemic had an additional challenge. The training and all communication of the Program has been online – but, lucky for us, it’s been really effective.

What were the first steps to get the Integrity Program done?
To find allies who would help me elaborate the action plan for the implementation and development of this project. Lucky for me I met Hannah Kim (from HR) and Kathia Oliveira (from Comms) that both helped me during the whole process, besides having the support of Mateus Furini (VP of Finance and Legal) and Taissa Cruz (Head of Diversity and Inclusion), who were fundamental for the success of the Program as well. Without them this project would not have gotten off the drawing board.

What about the pillars, how they came to be?
We wrote them between January and June – so we had five months to think about the program, set it up, benchmark it, present and take the implementation plan to the leadership for final approval. The go live was on June 29th and since then we have received constant feedback on how important it is to reinforce themes such as ethics and integrity in the work environment.

How was the construction of the Code of Ethical Conduct? And how Wilders have access to it?
As one of the most important documents and the “gateway” to the Integrity Program, we needed to develop something that would draw Wilders’ attention. That’s why I used visual law techniques (which employs visual elements to make the law clearer and more understandable) to make [the Code of Conduct]. We don’t want to use “Legal language”, so I joined forces with the design team to assemble the information with text and graphics and make this document more engaging and easy to understand.

What was the biggest challenge in creating this program for Wildlife?
We’re a tech company, so everything happens at a faster pace. So the biggest challenge was to adapt an Integrity Program for a company that is constantly growing and attracting investors. It’s not only about creating a positive image to Wildlife, but building something that truly makes a difference.

It was also crucial to create a global program, understand how the legislation in different countries works, as well as the culture and how it would be possible to create a single program for all the regions where we operate. Of course we had to make some adjustments to adapt some local rules, but we managed to develop a robust global program.

Was there a “Wildlife way” of making things happen?
There was no way I could launch this program with huge and complex documents. It needed to be clear and objective, with a creative footprint behind them, because Wildlife is a creative company by default. That’s why I decided to explore visual law. We’re talking about serious subjects there, so we need a lighter approach. That’s why we developed a robust communication plan so that people don’t forget the program and know exactly what it is.

I didn’t want to scare people with a bunch of guides, ’cause we needed to bring them together. Wilders are crucial to the success of the program, we needed to attract them from the very beginning. After all, their attitudes will influence the program’s success. There’s a very particular thing about Wildlife we want to nurture: that feeling of belonging. People live the company, and are passionate about what they do, and the Integrity Program comes to reinforce that.

What are the differentials you have identified in the sector?
I did a benchmarking with seven companies in the sector to try to understand how technology companies look at the question of ethics in the workplace. I’ve been trying to find out which would be the main asset of this project and I had very good insights – Diversity and Inclusion, for instance, will benefit a lot from it, because the program reinforces the importance of a safe work environment and mutual respect. In addition to ensuring that any conduct contrary to these premises will be properly addressed.

Have external factors also motivated this initiative?
There’s a global demand for programs like this to avoid undesirable situations, which we follow in daily news. The corporate world has started to value integrity programs specially in the past few years and companies now understand the need to create a safe space, and ignoring these issues is not an option.

It doesn’t mean that we have or will have a problem. But if we do, people will know what to do, who to look for and they won’t keep the experience to themselves – so they don’t get frustrated and end up leaving the company. The program exists to make people feel comfortable enough so they can bring up eventual situations they have witnessed or have experienced, and also to avoid those situations in the first place.

The importance of the program is to demonstrate that an ethical environment makes the difference and gives us a competitive advantage in the market to receive investments or dialogue with external stakeholders. Nowadays, a company that is committed to ethics in the workplace, that has a space of mutual respect among employees and that people feel comfortable to be who they are, is highly valued – and it shouldn’t be otherwise!

What positive effects do you see already since you’ve launched this program?
We know that when it comes to ethics and integrity the answers are not always obvious, so we noticed a great interest of our employees in the internal policies of the company, specially related to the Code of Conduct. We also noticed that Wilders wanted to help, acting as ambassadors of this initiative and reinforcing our concepts. It’s very gratifying to see Wildlife’s commitment to this issue. To me, Integrity Programs are extremely beneficial and I can’t imagine working in a company that doesn’t have clear behaviors related to ethics and integrity. It’s a worldwide program and it only works because Wilders believe in it.

Wildlife Oct 13, 2020 Melissa Cruz Cossetti