Culture shows up in the ledger

We compare what employees say about integrity with what overrides, exceptions and reports show in your records.

Part of
Ethics & Governance Assessments
Runs as
4 stages, from design to report
You receive
5 deliverables, listed below
Pricing
Quoted after a scoping call

Surveys measure belief, records show behavior

A culture survey asks whether managers act with integrity and whether staff would report a concern. The answers matter, but they describe what people believe, or what they want to be seen to believe. They do not show whether the sales director releases credit holds for favored customers, or whether the expense rules apply to the leadership team.

The DOJ's Evaluation of Corporate Compliance Programs asks how a company measures its culture of compliance and what it does with the results. ISO 37001:2025, the anti-bribery standard, now sets explicit expectations on culture too. A survey alone answers half of that question. We pair survey and interview evidence with tests of what your systems actually record.

Engraving of a carved barometer with a guilloche dial and a magenta quill for a needle.
Measure the weather inside.

Three sources of evidence, compared

  • Confidential survey

    A short survey on pressure, fairness, speaking up and management behavior, adapted to your company and reported only for groups of five or more.
  • Interviews and focus groups

    Conversations across levels, functions and locations that explain what the survey shows and find what it misses.
  • Ledger and system tests

    Overrides of credit and approval limits, self-approved expenses and entries, exceptions granted by seniority, and late or back-dated approvals.
  • Speak-up records

    Report volumes, categories, time to close, outcomes and what happened to reporters afterward, drawn from anonymized case data.
  • Leadership conduct in practice

    Senior leaders' expenses, related-party payments and approvals of their own transactions, tested under the same rules as everyone else's.
  • Incentives and pressure

    Bonus and commission plans, targets and covenants that can push people to bend rules, and how exceptions to those plans are granted.

Findings that compare words with records

DeliverableWhat it isWhen
Culture survey reportResults by function, level and location, shown only for groups of five or more, with comparisons between groupsWeek 4
Behavioral test resultsExceptions from ledger and system tests, each reviewed by an analyst, set beside what the survey says about the same areaWeek 5
Speak-up process reviewHow reports are received, triaged, investigated and closed, and what reporters experienced along the wayWeek 5
Culture assessment reportPlain-language findings ranked by consequence, with specific actions for leadership, managers and the boardWeek 7
Board briefingSession for the board or audit committee, with a plan to measure progress the same way next timeWeek 8

Survey, interviews and tests in parallel

  1. Weeks 1 to 2

    Design

    We agree the questions with leadership, adapt the survey, plan interviews and request data for the ledger tests.

  2. Weeks 2 to 4

    Field

    The survey runs for about two weeks while we hold interviews and focus groups and run the system tests.

  3. Weeks 4 to 6

    Compare

    We set survey results against interview themes and test results, and look for the places where they disagree.

  4. Weeks 7 to 8

    Report

    We present findings to leadership and the board, and agree owners and a date for the next assessment.

Access and voices the assessment needs

  • An employee list by function, level and location for survey distribution
  • Time for interviews with leaders and focus groups with staff across levels
  • Anonymized speak-up case data for the past two to three years
  • Ledger, expense and approval data for the behavioral tests, by read-only access or export
  • Incentive plan documents and the approval matrix
  • A sponsor on the board or leadership team who receives the report directly

Is this the right fit?

A good fit

  • Companies after a merger, a leadership change or a serious incident
  • Boards that want independent evidence about tone at the top
  • Private-equity owners assessing conduct risk in a portfolio company
  • Organizations preparing for ISO 37001 or answering investor questions on culture

Not the right fit

  • Employee engagement or satisfaction surveys focused on HR outcomes
  • Investigations of a specific allegation against a named person

Disagreement between sources is the finding

The most useful findings come from places where the evidence disagrees. Three illustrative examples of what that looks like:

  • Staff in one region rate their manager highly for fairness, but credit-limit overrides there run well above the rest of the company, all approved by the same person.
  • Survey answers say people know how to report a concern, yet the hotline has never received a report from operations, where most of the workforce sits.
  • Leaders describe a strict expense policy, and the card data shows its receipt rule waived for the executive team every month.

None of these proves misconduct. Each is a question leadership needs to answer, and the assessment puts it in front of them with evidence. When the channel itself turns out to be the problem, the guide to hotline setup for smaller companies is a practical place to start.

Small teams are protected in reporting

In a 120-person company, a team of four is identifiable even in aggregate. We merge small groups before reporting, summarize free-text themes instead of quoting when a quote could identify its author, and hold interviews by video or away from the office when staff prefer. Participants are told at the start what will be shared, in what form and with whom, and the report follows those terms exactly.

Pressure belongs in the picture

People rarely break rules for no reason. Quarterly targets, covenant tests, earn-outs and grant milestones create pressure, and pressure shows up as late entries, aggressive accruals and exceptions. We read incentive plans alongside the ledger, because an assessment that ignores how people are paid misses one of the main reasons rules bend. The behavioral tests come from the same library as our full-ledger analytics, tuned to conduct rather than fraud.

Each finding gets an owner

Findings are worth the change they produce. Every action in the report has an owner, a date and a measure that the next assessment will check. Where the speak-up process needs rebuilding, our code of conduct and speak-up work picks it up. Where managers need practice handling integrity conversations, training programs are built on the assessment's anonymized findings.

What people ask before hiring us

How do you keep responses confidential?

Results are reported only for groups of five or more, and free-text answers are edited to remove identifying details before anyone at the company sees them. Interview notes stay with us. Like all engagement data, they are deleted 90 days after the engagement closes unless you ask otherwise in writing.

Why test the ledger in a culture assessment?

Because behavior leaves records. If the survey says rules apply equally but managers' expense exceptions are approved far more often than staff's, the records answer a question the survey cannot.

Can we compare ourselves with other companies?

We report against your own earlier results and between groups inside your company. We never share or publish comparisons built from other clients' data. If you want an external benchmark, a commissioned benchmark study can be scoped separately.

How often should culture be measured?

We suggest a full assessment every two years and a short pulse survey in between, using the same core questions so results stay comparable over time.

Also in Ethics & Governance Assessments

Find out whether your culture, compliance program and board practice work as described, with evidence drawn from surveys, interviews and the ledger itself.

  • Compliance Program Evaluation

    A three-to-four-week diagnostic that answers the DOJ's three questions about your compliance program, using documents, interviews and data, and ranks the gaps by consequence.

  • Board & Governance Review

    A three-to-four-week diagnostic of who holds authority, how conflicts and related parties are handled, what the board reads and how its decisions are recorded.

Related work and reading

  • Code of Conduct & Speak-Up Programs

    An eight-to-twelve-week project that redesigns your code of conduct and builds the reporting channel, triage, investigation protocol and anti-retaliation process behind it.

  • Full-Ledger Analytics

    A two-to-four-week diagnostic that runs a library of explainable tests and outlier models over every transaction in the period, then reports only the flags an analyst has reviewed.

  • Training Programs

    Half-day sessions to six-week cohorts for managers, staff and boards, built on your policies, your approval limits and anonymized examples from your own ledger.

  • A code of ethics employees actually read

    Most codes are written to be signed, not used. Rebuild yours around the decisions employees face, with plain questions, real limits and a named person to ask, and test whether people can find answers in it.

  • Whistleblower hotline setup for smaller companies

    A speak-up channel works when reports reach someone independent of the people named, get triaged within days and never cost the reporter. Under the DOJ pilot, a company's 120-day clock starts with the internal report.

  • Twelve questions boards should ask the CFO every quarter

    A quarterly question set for private-company and nonprofit boards, covering close quality, cash controls, the hotline, related parties and AI use, with good and worrying answers side by side.

Tell us what you are seeing

A first conversation is a scoping call: what worries you, what you need to show, and to whom. You leave it with a view on where to start, whether or not you hire us.

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