July 22, 2013
Mr. José Graziano da Silva
Director-General
Food and Agriculture Organization of the United Nations
Viale delle Terme di Caracalla
00153 Rome, Italy
Re: Ombudsman/Ethics Officer Role
Dear Mr. da Silva,
On behalf of the International Ombudsman Association (IOA) I would like to commend you for your plans to establish an organizational ombudsman office within the Food and Agriculture Organization (FAO). As you are certainly aware, effective organizational ombudsman programs provide great value to organizations around the world as they help resolve conflict efficiently in the workplace, help to identify systemic issues that can pose enterprise risk and serve as an early warning system to help mitigate emerging issues. As you know, the United Nations-Bretton Woods system has several organizational ombudsman programs that exemplify excellence in our profession.
A few years ago, an impressive description of the organizational ombudsman role consistent with best practice was posted by the FAO (which is enclosed hereto), a process that subsequently may have been halted for a period of time. While I am encouraged that the FAO is now continuing towards establishing an organizational ombudsman Office, I also would like to express my concern regarding the changes in plans that combine the Ombudsman and Ethics Officer roles. This combined structure can pose practical and perception problems for those the office serves, the organization, and of course, the program itself. As has been demonstrated through years of practice in the field, combining informal and formal offices can diminish, if not eliminate, the benefit of the informal role as the functions are intended to be inherently different.
A paradox of the organizational ombudsman role is that the ability for a practitioner to be effective actually comes from the fact the person does not have any formal authority and works confidentially, impartially and independently outside the lines of management. This is why the IOA recommends that the Ombudsman’s Office and the Ombudsman’s role are structurally and functionally independent to the highest degree possible and avoid actual or perceived conflicts of interest that may be created by affiliation with other organizational structures and diminish its credibility. An independent structure is critical in earning and building trust with staff and recognizes certain realities and impediments that may prevent staff from approaching the resource if it lacked clarity in structure and function.
Many issues that would otherwise never be surfaced in an organization – due to real or perceived threats of retaliation, for example – are shared with Ombudsman Offices since people know the concerns can be discussed in an informal, off-the-record environment unattached to other organizational arms, and in a safe environment where speaking with the Ombudsman does not in itself give notice to the rest of the organization. The Ombudsman can then assist the parties involved in finding ways to raise the issue to resolve problems at the lowest and most efficient level appropriate for the situation.
When the informal organizational ombudsman role is combined with a formal role, such as an Ethics Officer position, the effectiveness of the organizational ombudsman is immediately lessened since the person in that role would be in conflict with responsibilities and obligations created by the formal role, such as being an organizational agent for receiving notice. Contrary to an organizational ombudsman, an Ethics Officer would have an obligation to act on information received and therefore people would likely not trust or share information in the way they would with someone who was only holding an organizational ombudsman role rather than a combined one.
To help illustrate, at FAO, The Ethics Office “promotes compliance with the organization's rules, policies and procedures, and contributes to fostering a culture of ethical behavior, transparency and accountability.” (Ethics Office website) While an Ombudsman Office may lead to an impact of increased compliance or ethical behavior because individuals feel safe to raise their concerns, are informed of policies and options, and independently decide to choose a certain course of action, the Office itself cannot hold a position on, require or promote courses of action because of the duty of maintaining impartiality and neutrality.
When such positions are combined there is a high likelihood of confusion among roles, and there is a danger that employees of the organization might believe they are working with an informal resource when in fact a person with a dual role, such as the one being currently proposed, may be compelled to act formally. In addition, although in theory, combining the two roles and expecting an individual practitioner to fulfill the two separate functions may seem doable, in actual practice it can be extremely challenging for the practitioner because they create conflicts. The lack of clarity and confusion can result in unexpected, unintended consequences for the organization.
The International Ombudsman Association makes these distinctions very clearly in both our membership structure and our certification program. For practitioners to be full members of the Association, as the Ombudsmen from several of the UN-Bretton Woods system are, they must comply with the IOA Standards of Practice and Code of Ethics (for your convenience, I have enclosed these documents). This includes holding no other role that would limit an Ombudsman’s ability to function informally, confidentially, informally or independently. The requirements to become a Certified Organizational Ombudsman Practitioner require the same.
Beyond these important considerations, there is also a message that people within an organization will infer from such a structure. This includes a question regarding whether the organization understands and values the nature of an organizational ombudsman program and the way in which it serves employees. It may also raise questions around why industry best practice is not being followed in the organization while there are other examples present. These questions could significantly detract from the ability of an Ombudsman Office to adequately serve an organization and for the organization to have an effective program.
Again, I commend you for your interest in establishing this important service for the FAO. At the same time, I respectfully request you consider separating the Ombudsman and Ethics Officer roles. I believe that doing so now, at the early stages, will provide your organization with the full benefit of what an organizational ombudsman office can provide, and avoid future impacts that are detrimental to your intended purposes and out of alignment with identified best practices in the international organizational ombudsman community.
I would be happy to speak with you regarding best practices and can provide extensive resources in supporting the development of your organizational ombudsman office through the International Ombudsman Association.
Respectfully,
Anamaris Cousins Price
President
International Ombudsman Association
En: 2010 FAO Ombudsman Posting
IOA Code of Ethics
IOA Standards of Practice
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