Mary Shirley, how would you define a culture of integrity?

We will have an unique opportunity to meet Mary Shirley at the Nordic Business Ethics Day on April 29. Mary will talk about establishing a baseline understanding and some practical inexpensive suggestions for implementing culture of integrity as well as a run through of some of the most common challenges to achieving a culture of integrity and how to overcome them.

Mary is currently global Head of Culture of Integrity and Compliance Education at Fresenius Medical Care.  Mary also hosts the Great Women in Compliance Podcast which aims to create a platform for the outstanding achievements of women in the field and sharing ideas and providing learning opportunities for everyone in Compliance. 

Just to get to know Mary before the live stream, we wanted to ask a few questions from her on her favourite topic; a culture of integrity. Mary, How would you define a culture of integrity?

“Defining a culture of integrity is difficult. I am reminded of the 1964 case when Justice Potter Stewart attempted to define obscenity. He said “I shall not today attempt further to define the kinds of material I understand to be embraced… but I know it when I see it…”

We certainly know with an almost gut wrenching instinct and emotive response what a toxic culture looks and feels like. A culture of integrity is one where no matter what our different backgrounds and perspectives, we universally know it when we see it. If I was to distill the individual components, for me the ingredients for such an environment are: psychological safety, accountability to own and commit to shared values enshrined around doing the right thing, transparency – showing how the sausage is made proactively, not just when in a corner, and reliability – the community of stakeholders are true to their word and no matter how privileged or powerful one might be in the community, they are held to the same standards as everybody else.”

Thank you Mary, I definitely agree with you – and really like your metaphora (I think I’m gonna steal the sausage example :)). What can everyone of us do to promote integrity at work?

Mary: “Look in the mirror. Is the face staring back at you one which you can look in the eye when asking whether you have done right by your values and the people around you? Not just the people you hold dear but the stakeholders that form part of your universe as well? If you don’t like what you see, make the changes that will allow you to hold your head high and sleep well at night. Sometimes that means tough decisions. It can mean giving up relative security and certainty of a regular paycheck to enter the job hunt again for the reward of joining an organization that prizes the same ethical values that you do. I have found that making tough decisions to remove yourself from the Stockholm Syndrome of “the devil you know” for something better aligned with your true beliefs and values or people who treat you as an equal and with due respect is always worth the leap of faith – trust me, you won’t look back.

Mary, how do you see the shift within the Ethics & Compliance community? Should ethics, integrity and focus on corporate culture be a top-of-mind for every compliance team?

“The Compliance discipline continues to shift from Compliance Officers as regulatory compliance disciplinarians to the ethical and almost moral guardians of organizations. Companies that do not embrace the shift and seek to understand and mitigate risks for what subject matters could result in reputational damage are the ones that will be left behind. The field has been moving towards culture of integrity as a priority for several years, and more recently started to embrace ESG, including social justice as part of the evolution. Where are you if your Compliance function is not evolving and continuously shifting its embrace too?

That’s a great question to leave for the reader to think about. Looking forward to hear more of your thoughts in the Nordic Business Ethics Day on April 29! Thank you Mary Shirley!


Mary Shirley is a New Zealand qualified lawyer with 15 years of Ethics and Compliance experience working for data privacy and antitrust regulators, in-house and private practice/consultancy. She is currently global Head of Culture of Integrity and Compliance Education at Fresenius Medical Care.  Mary also hosts the Great Women in Compliance Podcast which aims to create a platform for the outstanding achievements of women in the field and sharing ideas and providing learning opportunities for everyone in Compliance. She co-authored book Sending the Elevator Back Down: What We’ve Learned From Great Women in Compliance (CCI Press, 2020).