Live Bait & Ammo # 82
When it comes to humor you can’t beat the truth. On August 21, 2006 Apollo, Delphi’s official employee communication network, announced: “Compliance is Everyone’s Business: An Interview with David Sherbin”
It’s comforting to know that there exists a “Chief Compliance Officer” who, in his own words, encourages “any Delphi employee to call, write, or email me with ideas, thoughts, and even complaints about the compliance program.”
The knowledge that someone appointed by the Board of Directors has the will and the power to hold the unscrupulous accountable lends credence to the questionable and trust to the double standard. A display of honesty in the leadership inspires the ranks with confidence to conform with the drill no matter how “irregular” it may appear on the surface, or beneath as the case may be.
Since Brother Sherbin didn’t include his contact information in the interview, I called the Delphi Ethics Line [1-888-679-8848] and asked Sister Snitch to put me in touch. But I’m jumping ahead. First, some excerpts of the actual interview between Apollo and the Chief Compliance Officer, David Sherbin.
Apollo: “What do you mean by Ethics?”
Sherbin: “Ethics usually means a strong moral code and doing what is right.......What we need to assure is that the pressures of business and competition don’t encourage any of us to take ‘short cuts’ or ‘bend the rules just a little bit’ to gain an edge.....Good people can make bad choices if they don’t have a framework that helps them make the right choices, and we want to make sure at Delphi that people always make good choices.”
Apollo: “Why are we doing this now? Did we do something wrong?”
Sherbin: “My appointment and the development of a formal Compliance Program is more about doing things right than a response to any specific events or problems within Delphi.....We have had problems including certain accounting irregularities that led to our financial restatement. To make sure similar problems, or new ones, do not occur again, we must make compliance with laws, regulations and our own internal Delphi standards part of our corporate ‘DNA’.”
Apollo: “How can we help?”
Sherbin: “Building a compliance culture is about each of us taking individual responsibility for our own compliance and collective responsibility for our team’s compliance. It means we need to step up and say, ‘That’s not right’ when we see a potential violation....”
Apollo: “A lot of employees are nervous about using the Ethics Line. I hear a couple of comments consistently — ‘Do you really expect us to snitch on each other when we see things we think are wrong?’ and ‘Nothing will happen if I call except I might lose my job.’ What are your thoughts on this?”
Sherbin: “.....Raising critical compliance issues is not ‘snitching’ — it is really protecting everyone’s jobs. We try our best to maintain the confidentiality of the Ethics Line process, even when callers do not request it. I can also tell you that if we ever find out that someone has retaliated against a Delphi employee for calling the Ethics Line in good faith, we will take immediate disciplinary action, up to and including termination.”
Just like Apollo I have heard the same “comments consistently”— fear of snitching on peers and getting the old goose whacked. But I’m all for “protecting everyone’s job”. So I dropped a dime and used an alias.
ME: Hi. This is Ed Northern. I work for a Delphi plant in the United States.
Sister Snitch: Hi, Gregg. Let me guess. You work in Coopersville, MI. in department 988, B-shift, Line 5, Final Assembly Bodine. You are 56 years old, five-foot-five, 130 pounds...
ME: I’m bigger than that.
SS: In your sleep....married with three children, and your social security number is...
ME: Hey, I thought this was supposed to be confidential.
SS: My lips are sealed and this conversation will be recorded for your protection.
ME: My protection against what?
SS: Getting your goose whacked for snitching on your peers and desecrating the good name of Delphi in public.
SS: Everyone in Compliance will receive a copy of your taped confession for review and retaliation.
ME: From now on call me Ed, or Mr. Northern.
ME: Delphi is selling scrap.
SS: Is that your compliance issue? Forgive me. I thought you had something juicy. What’s wrong with making a little money on scrap? Are you against the profit system? Are you a communist? Don’t you believe in recycling? What do you expect us to do? Throw money away?
ME: We already did throw it away. I don’t know why or how they managed to keep these parts around so long because we scrapped them out three years ago but they’ve hauled a shit load of defective parts back into our shop and workers have been ordered to black out the serial numbers and dates and etch new serial numbers and dates and then we ship them to .....
SS: Sounds like job security. Are you against working for a living? When was the last time you pledged compliance to the flag?
ME: You mean allegiance.
SS: You can allege whatever you like but the fact you made this call proves that you are not in compliance with the Delphi code of silence. Besides, the product you call scrap will be repurchased by Delphi. It’s the accounting that confuses you, not the facts. All systems comply automatically in accordance with our Universal Reciprocal Process.
ME: Forget it. I have another complaint. Representatives from Delphi headquarters held captive audience meetings in our plant at which they persuaded employees to invest their life savings in Delphi stock under false pretenses and now the stock isn’t worth crap.
SS: So what are you saying? We didn’t sell enough scrap or we sold you a bunch of crap? What is it?
ME: Both! Scrap and crap are both violations of compliance.
SS: Look, if you hadn’t wasted so much time complaining about scrap, what we told you wouldn’t have amounted to crap. Compliance is nothing in essence but a disposition to yield to the will of authority. Since Delphi is the WILL and the WAY you are the one indisposed to yield and thus ultimately responsible for the failure to aid and abet the delivery of scrap to customers in Delphi’s Advance Complicity Program so we could buy it back at a mutually beneficial profit and thereby double the return on your investment.
ME: I never thought about it like that. Compliance is not in itself a defined standard, but rather the appearance of unquestioning conformity and the Chief Compliance Officer is thus, the King of Crap.
SS: Your complaint will be processed in the order it was received. Anything else, Gregg?
ME: Ed. I’m ED NORTHERN for the record. I insist that you honor my confidentiality by referring to me by my allegorical alias: ED NORTHERN, patriot, christian, and penultimate good old boy.
SS: Whatever. Are we done?
ME: Delphi is paying people out of the JOB Bank account who are not in the JOB Bank.
SS: So what? I thought you liked JOB Bank. I thought all you guys liked the rubber room. I thought bouncing off the walls is what you do best.
ME: Paying workers out of the JOB Bank fund when they are not actually in the JOB Bank but are actually continuing to function in their appointed positions is what one might call an “accounting irregularity” or double bookkeeping.
SS: Are we talking about appointees or workers? Because they are not one and the same.
ME: We are talking about workers doing appointed jobs. Delphi has taken them off the payroll and put them in the JOB Bank to make the operation look more efficient than it actually is. Then Miller complains about the cost of the JOB Bank. It’s a scam.
SS: According to the Delphi Employee Redundancy Program appointees are categorically in the JOB Bank because they don’t add value to the product and if it wasn’t for nepotism they would all be fired.
ME: I can’t argue with you about the nepotism but paying them out of a separate set of books is fraud.
SS: One moment. I am connecting you with the Chief Compliance Officer.
CCO: I understand you used the F-word. Do you know what we do to employees who use the F-word?
ME: Is this where the compliance comes in?
CCO: I don’t answer questions. I ask questions.
ME: Then ask yourself why Delphi should get away with underfunding the pension while simultaneously investing in assets overseas which are sheltered from bankruptcy...
CCO: Congratulations, Gregg, you’re a perfect candidate for our compliance program.
ME: My name is Ed. ED NORTHERN: christian, patriot, and goddamn good old boy from...
CCO: And you have won, yes you, Gregg, have won an all expenses paid adventure to Compliance Island where you will experience total immersion in the Delphi Manufacturing System.
ME: I don’t want....
CCO: Don’t worry. It’s entirely virtual. You won’t feel a thing.
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