Many businesses have compliance officers. It is the responsibility of these members of staff to ensure that a firm complies with all the legal and regulatory requirements laid upon it. However, I am going to suggest that there is a different understanding of compliance which is a significant dimension in the various scandals that have come to light in recent months. Whether it is the Post Office, or the entire system of politics and health care provision, in the case of contaminated blood, something has led seemingly intelligent and responsible people not only to fail to act, but to actively work to suppress concerns and continue with dangerous treatments for which other – safer – options were available. What has led these people to comply with behaviours and a culture they knew to be wrong?

Organisations are very good at suppressing criticism. Even when there are good policies and procedures for raising concerns, unspoken influences shape the course of action people feel able to use. For example, without overwhelmingly compelling evidence – and other willing witnesses – the balance of power sits with management. Managers organise rotas; authorise annual and compassionate leave requests; they write appraisals and references. Suggesting that something is wrong means that a manager has allowed something to happen under their watch; been so ill-informed as to be unaware; or are directly complicit in some aspect of a negative culture. In all circumstances it is a risk to whistleblow, whatever paper assurances exist in corporate policies. Even if nothing negative happens at the time, managers may salt away their feelings about the employee and save their retribution for a future time when their action, and past events, can no longer be connected.

Sometimes chaplains fail to recognise these dynamics and express their views with naive candour. I have known several chaplains over the past couple of decades who decided to raise a concern directly with a CEO or organisational chair. This may be no bad thing, but it can irritate all the managers they have cut out between their organisational position and the top of the chain. Perhaps, in the spirit of naval chaplains, the chaplains regard themselves to be the equal of whoever they happen to be addressing. In some cases they have not even bothered to voice their concerns internally but, in the first instance, have gone to an external party. This kind of behaviour was picked in early drafts that led to the NHS England chaplaincy guidance of 2003, Caring for the Spirit. At one point there was text to the effect that chaplains could offer critical insights about an organisation, so long as this did not come as a surprise to that organisation. In other words, chaplains should escalate things internally before writing to their bishop etc..

The problem with internal escalation is that it can be stimied in a number of ways. I have seen on many occasions how the legitimate concerns of a chaplain have been reinterpreted and dismissed while, at the same time, subtle changes may have been made quietly in the background. While it is good that a chaplain’s observations might help put things right, it may also have marked the chaplain out as a troublemaker as far as management was concerned. Organisations possess a gravity that bends behaviour towards various degrees of compliance.

Watching the recent questioning of the former Post Office CEO, Paula Vennells, I was struck by the complete absence of shame in the testimony. There were tears; apologies; and a lot of regret that she had been poorly advised, but no shame. This was an organisation that persecuted and prosecuted its own staff; trusted a faulty software programme more than people; and defended its wrongful actions long after it was clear that reasonable doubt existed about Horizon. At least one person caught up in these horrors committed suicide, and many others were falsely imprisoned. Surely the person who sat at the top of such an organisation, receiving an enormous salary and bonuses, would be ashamed to say they were in charge? Yet that was not the impression given during the testimony.

“A certain kind of shame is valid in its proper context. If you do something morally wrong – steal a colleague’s idea or make a promise you don’t intend to keep – you should regret it, feel guilty, even ashamed of your actions. That’s not unhealthy. It might lead you to apologize and might prevent you from doing it again”.

This Leadership Motivation Is Toxic. Here’s Why You Shouldn’t Do It by Erica Ariel Fox, Forbes Magazine 5 December 2022

All this suggests that the training and formation of senior managers gets so invested in processes and operating systems that some of the core humanity of leadership gets left behind. In the case of the Post Office, the voices of staff working in the branches were given remarkably little weight. To meet financial targets, and defend an eye-watering investment in Fujitsu, people were simply thrown overboard. If that isn’t something a leader should feel ashamed about, then our selection and development of leaders needs a serious overhaul.