Government of India, Ministry of Defence

A Miniratna Category-1 Company

make in India swachha bharat


CVO's Desk

Vidya Bhushan Kumar,IFS
Chief Vigilance Officer

Dear Friends,

I have experienced that most of the managers think of ethics as a purely personal matter and any misconduct of an employee is construed as an isolated incident, the work of that person only. They do not consider that individuals misconduct isalso influenced by organization culture. It is difficult to fully explain the misconduct of an employee purely from character flaws of a lone actor. In fact, the deviant behavior of an employee is resultant of complex interaction between his personal ethics and organization ethics. Therefore, ethics is as much an organizational as a personal issue. So, it is equally important to address organization ethics and integrity and shape them both, for guiding an employee’s conduct and, for company’s sustained growth.

Organization ethics is the application of choices based on values, rules, regulations and strategies associated with an organization’s activities. It is generally seen how an organization interacts with external situations. It is an admitted fact that maintaining organizational integrity pays rich dividends in long run.

The general approach to ethics management has been compliance or rule based which aims to prevent misconduct by complying externally imposed standards e.g. legislations, strict codes of conduct etc. This approach overemphasizes the threat of detection and punishment in order to channelize behavior in lawful directions. The role of vigilance under this approach is both preventive by doing system analysis and prescribing systematic improvements and punitive, by recommending action against the violators.

However, this approach has got its limitations. The other approach namely, integrity or value based approach has evolved in recent times, which goes beyond the realms of current mandate of vigilance functioning, and aims to stimulate ethical behavior and responsible conduct by self-governance. In this approach, focus is to develop company’s values and standards; training and communicating, coaching and guidance, identify and help in resolving problems and oversee compliance activities. This approach brings a concern for the law with an emphasis on managerial responsibility for ethical behavior. It demands active role and efforts of managers at all levels. The need to obey the law is viewed as a positive aspect of organization life, rather than constraint imposed by outside agency.

Both the approaches are necessary for management of organization ethics. In fact, they are complementary and compensate for each other limitations. While rule based approach helps with preventing unethical behavior; the value based approach helps with supporting employee in dealing ethical dilemmas.

In order to develop a holistic approach to integrity management framework in our company, value- based approach must also be given due attention. This could be done if we immediately address followings:

    • Evolving code of ethics (values- based) in addition to code of conduct (rules- based) ;
    • Gifts and gratitude policy: essential element should be that all gifts be reported to management;
    • Effective post public employment policy;
    • Conflict of interest policy: making staff sensitive for problems and encourage them to systematically report problems;
    • Inclusion of integrity as criterion in personal management (like selection and evaluation of promotion), procurement policies, financial management, information management and privacy and quality management.
    • A well-developed ethical training program for various levels of staffs should be put in place;
    • Integrating integrity into the organizations daily discourse through magazines, website, targeted mailing;
    • Regular discussions of ethical dilemmas in official internal communication like internal magazine, intranet;
    • Institutionalizing discussion of integrity issues in staff meetings, supervisor –employee meetings;
    • Creating an open culture of communication and specially bringing all integrity related issues on table.
  • An effective Whistle – blowing policy constitutes the most important measure for monitoring of integrity in an organization. It aims to solve problem before it becomes a scandal. Although it is mandated by Company Act to put in place a vigil blowing mechanism in all the registered companies, its success lies in its effective implementation.  It is not the core element of ethics management, but an essential safety net.
  • Enforcing of Integrity through informal sanctioning and by adopting fair and appropriate procedures for investigations and sanctions.


In fact, Active Leadership Support is the most significant factor for success of any ethics management plan. The support must be explicit and forceful to ensure there are sufficient means for integrity management and paying adequate attention to integrity in communication.

When allegations of misconduct do surface, the company must deal with them openly. The objective should be to develop both Moral Manager and Moral Person. The efforts of management should be to stimulate integrity among their staff by correcting unethical behavior, creating an open culture where staff can be open about their mistakes and discuss their dilemmas.

The management must encourage staff to exhibit exemplary behavior and develop Integrity Actors and such behavior must be appreciated openly by the management. This is more relevant for officers / employees at key positions including employees elected representatives, whose conduct has potential to be emulated and followed.

It is my considered view that effective resolution of ethical dilemmas in daily official work is the building block for development of sound and robust ethical management framework and organizational integrity. A holistic approach will ensure that they do not only prevent integrity violations but also support employees in dealing with ethical dilemmas.

Let this year’s Vigilance Awareness Week is triggered by adopting this holistic approach to organizational ethics management. We, as a company, should strive to maintain organization integrity where “We will do what We say We will do”.  We should pledge to create a healthy environment within our company to help flourish right kind of ethics and integrity and support integrity actors not only for sustained growth of the company but also to eradicate corruption and build a New India- theme of 2018 Vigilance Awareness Week.