The objective was to assess the maturity of the U.S. Postal Service Ethics Program in three areas: (1) agency goals and metrics, (2) accountability and consistency, and (3) cause and prevention. We discuss these areas using a maturity model framework to demonstrate the value of approaching an organization’s ethical efforts in a comprehensive, integrated manner that actively contributes to the organization’s mission.
The Ethics in Government Act of 1978 (Ethics Act) established the U.S. Office of Government Ethics (OGE) which oversees and determines compliance with the executive branch ethics program, the mission of which is to prevent conflicts of interest on the part of executive branch employees. In its latest review, the OGE identified two issues related to the Postal Service’s annual ethics training. Both have been resolved.
The ethics branch of the Postal Service Ethics and Compliance Office (Ethics Office) is responsible for overseeing compliance with the Ethics Act. The overall mission of the Ethics Office is to familiarize all Postal Service employees with the ethics laws and regulations that apply to employees of the executive branch. The chief ethics and compliance officer describes the Postal Service Ethics Program in terms of compliance with the requirements of the Ethics Act, ensuring the Postal Service is applying the standards of conduct, and advising the managers of individuals involved in misconduct.
For this audit, the U.S. Postal Service Office of Inspector General (OIG) did not evaluate whether the Postal Service complied with Ethics Act requirements as mandated by the OGE. Rather, the OIG took a broader perspective of ethics programs. In our approach, an ethics program reaches beyond the mission of the Ethics Office and encompasses the organization’s and employees’ ethics-related obligations that are external to the Ethics Act.
This broader program engages groups across the organization in active coordination and communication to facilitate accountability and foster organizational consistency while generating reliable metrics for analysis and decision making. We included analysis of the benefits of tracking unethical activities that affect the public trust, involve dishonesty, and/or the appearance
that laws have been violated.
We employed maturity models to provide a framework for assessing the state of the program and developing improvement plans to achieve the desired levels of maturity. Maturity models are models of organizational improvement that are built on the premise that organizations involved in complex endeavors move through levels of effectiveness. As organizations become more experienced in those endeavors and develop effective systems supporting the activities, they become more mature in their approach.
We designed the maturity models for the Postal Service environment by leveraging guidance from respected audit and compliance and ethics program sources. Within our models, maturity levels range from Level 1: Non-existent (low maturity); Level 2: Reactive; Level 3: Defined; Level 4: Mature; to Level 5: World Class (high maturity). The center of our scale is Level 3: Defined. At this level of maturity, an organization has defined formal policies and codes of conduct and ethics that are promulgated to all employees.
What the OIG Found
Based on our analysis of Postal Service processes in place for three areas of the ethics program during calendar year 2017, the Postal Service demonstrated maturity between Level 3: Defined, and Level 4: Mature, with some indicators of Level 5: World Class attributes for the agency’s goals and metrics and accountability and consistency areas. For example:
- Agency goals and metrics – The Ethics Office incorporates into its annual goals specific performance targets for the number of ethics training events and is using technology to improve efficiency. However, they could better assess training effectiveness and expand maturity in this area by performing more in depth metric analysis of trends in Ethics Helpline request topics following ethics training.
- Accountability and consistency – The Postal Service has written policies and directives establishing employee responsibility and accountability, a written policy of non-retaliation, and a process for responding to allegations.In addition, there are organization-wide communications describing the nature and consequences of ethics violations and unethical activity. However, maturity in this area could be enhanced by establishing organization-wide guidance outlining a common process for determining the appropriate actions in similar cases.
We also determined that the Ethics Program does not focus specifically on the cause and prevention area. A focus on cause and prevention identifies the root causes of unethical conduct and uses the information to prevent further lapses. Each organization independently determines the ethics program areas that best reflect and support their organization’s mission, as well as the desired maturity for each area.
A more mature ethics program prioritizes ethics in concert with operations and better leverages data and resources to support the organization’s performance measures and goals. The Ethics Program and, in turn, the Postal Service, could be enhanced by developing a more comprehensive, integrated program where ethics-related work in various groups across the organization is well-coordinated and leveraged to better support the organization’s mission.
Further, an integrated, comprehensive ethics program could help the Postal Service reduce employee misconduct and unethical activity, protect its brand, and maintain its reputation as a trusted entity.
What the OIG Recommended
We recommended management:
- Establish a cross-functional committee to create and provide oversight for an organization‑wide, integrated approach to the Postal Service Ethics Program.
- Adopt an approach for assessing the effectiveness of the ethics program by:
- Identifying priority areas.
- Designing the goals for each ethics program priority area to support the mission and organization-wide goals.
- Identifying the desired maturity level for each ethics program priority area.
- Devise metrics, collect necessary data, expand analyses, and connect related metrics in each ethics program priority area to monitor progress toward the target maturity level and the goals of the organization’s ethics program.