Food Hygiene Essentials

Preface

By Andy Routledge

It is true to say that most people have an inherent interest in integrity and ethics to a large degree. Much In the same way that the vast majority of road users have an inherent interest in road safety. We all want to be able to rely on certain things in life to remain safe, reliable, trustworthy and fair. After all, certainty is the first of our human needs. For Instance,  if we were to take a senario concerning food, we all rely on the butcher to sell us fresh and uncontaminated meat, we expect him to work hygienically and we also expect him to buy meat that has been humanely slaughtered in a legal establishment and to charge us a reasonable price for what we buy.

None of us want to buy from disreputable, dirty and underhanded businesses. We all rely on the integrity and ethics of those that supply our products and services and we  would be  disappointed and understandably annoyed if were to find out that we have been treated unfairly and dishonestly. Likewise, others rely on us to act similarly fair  in areas for which we are responsible. This is one of the founding principles of social order and reciprocal existance. People who disregard this inherent need of ours to safeguard certain basic principles and standards put both us and the rest of society at large, at risk. It would be blatant abuse of our trust to provide products or services of a lower standard  than that for which we are paying our well earned cash. We are willing to readily give our loyalty to those businesses that take care of our interests with ethics and integrity. It is, therefore, in the long term financial interest of such businesses to keep us coming back by continuing to perform to our satisfaction. Such businesses will prosper much better in the long term than will those businesses who are simply out to make a quick buck.

The article below goes into the subject of integrity and ethics in depth and in a way which explains the topic very well. Although the text does not directly speak of issues that relate to food hygiene, the general flow and context relates to any business scenario. It is for this reason that I find it relevant to put this article onto the blog. You are invited to send this article to as many people as you like. In my opinion everybody will benefit from reading it, especially businesses. Enjoy!

Introduction

We start by answering head-on the questions
“What is Integrity?” and “What is Business Ethics?”
We do this in a way that is analytic but which we
hope is easily understood by the majority of our
audience. Whilst we believe that most people have an
intuitive sense of right and wrong, it is clear that an
analytic understanding of integrity is no longer a
significant part of our educational or cultural
curriculum. This makes integrity difficult to
implement in practice as people try to resolve issues
of principle and profit in their working lives. Indeed,
some people even fail to recognize that they are
facing an ethical decision.
We also believe that the conflict between people’s
intuitive sense of doing what is right and the
practical demands of their job generates a lot of the
stress felt by many. Regulation is not the whole
answer to people’s work place dilemmas. In some
respects, financial regulation has created an
atmosphere of fear that a mistake will be fatal; and
this can develop into a hatred of compliance, which
is perceived by many as a “necessary evil”. Employees
are sometimes bullied into collusion and coerced
into finding profitable “work-around” of regulations.
Feelings of shame are far too common, with many
employees in financial services coming to work only
to hang up their personal values next to their coats.
This condition can be described as “workplace
schizophrenia”, in which people feel they cannot
bring their whole self to work. This disjunction can
in itself be described as a lack of integrity in their
lives. So there may be a paradox in the present
situation, namely, that the time and energy devoted
to compliance may detract from a broader awareness
of “workplace integrity“.
We describe integrity in terms of its component
virtues, or “values” as we call them today. We identify
the excesses and vices which are often so apparent in
financial services. But we remember that the client
too must have integrity. Investor or consumer greed
is as corrosive as the behavior of those who pander
to it.
We believe that integrity is a journey, not a
rulebook. Rules and regulations cannot cover every
possible ethical dilemma and there is always
something new to discover about how to approach
conflicts of interest.
Furthermore, we believe that personal integrity
cannot flourish outside a context of corporate
integrity. Only when every individual completes a
personal journey of moral and ethical reflection, can
we collectively complete the virtuous circle of
integrity.

Imagine you are walking down Thread needle Street
in the City and you find an envelope lying on the
pavement. You pick it up and find it contains
$10 million in bearer bonds, which anybody can cash
in. Do you hand them in to the police or take them
to a dubious offshore bank and retire? The only
reason for not keeping the bonds is because handing
them in is the right thing to do, and doing the right
thing means you will lose out.
Some people in Financial Services want to
understand morality better because they have seen in
recent financial scandals how bad behavior was
clearly bad for business. They know that good
behavior is good for business, so they want good
behavior; this is called the business case for ethics.
Others, however, want good behavior simply
because it is good and because it is right, even if such
behavior might be seen to be bad for business in the
short term. Now you may think that the outcome is
the same, both groups want to act fairly and morally,
so never mind their different motivations. Think of
our opening example, however; does the business case
for ethics lead you to hand in the bonds?
The approach of this paper can be characterized by
the words we use to describe Financial Services. The
Financial Services sector is usually referred to as an
industry; this paper will suggest that a more helpful
way to describe Financial Services is that it should
have the attributes of a profession. A professional not
only gets paid for his expertise but also for his
integrity.
Integrity is a word widely used in business today
but its meaning is rarely defined, even in Annual
Reports or corporate Codes of Ethics. In this paper,
we define integrity as those shared values, attitudes
and behaviors that help us to act correctly in our
lives at home, at work and in society.
2
1.What is Integrity?

Imagine you are walking down Thread needle Street
in the City and you find an envelope lying on the
pavement. You pick it up and find it contains
$10million in bearer bonds, which anybody can cash
in. Do you hand them in to the police or take them
to a dubious offshore bank and retire? The only
reason for not keeping the bonds is because handing
them in is the right thing to do, and doing the right
thing means you will lose out.
Some people in Financial Services want to
understand morality better because they have seen in
recent financial scandals how bad behavior was
clearly bad for business. They know that good
behavior is good for business, so they want good
behavior; this is called the business case for ethics.
Others, however, want good behavior simply
because it is good and because it is right, even if such
behavior might be seen to be bad for business in the
short term. Now you may think that the outcome is
the same, both groups want to act fairly and morally,
so never mind their different motivations. Think of
our opening example, however; does the business case
for ethics lead you to hand in the bonds?
The approach of this paper can be characterized by
the words we use to describe Financial Services. The
Financial Services sector is usually referred to as an
industry; this paper will suggest that a more helpful
way to describe Financial Services is that it should
have the attributes of a profession. A professional not
only gets paid for his expertise but also for his
integrity.
Integrity is a word widely used in business today
but its meaning is rarely defined, even in Annual
Reports or corporate Codes of Ethics. In this paper,
we define integrity as those shared values, attitudes
and behaviors that help us to act correctly in our
lives at home, at work and in society.
2
If it’s legal then surely it’s ethical?
The economist Milton Friedman argues that “there
is one and only one social responsibility of business
- to use its resources and engage in activities
designed to increase its profits so long as it stays
within the rules of the game, which is to say,
engages in open and free competition without
deception or fraud”1.These “rules of the game” are
to be understood as a particular society’s laws. In a
nutshell, Friedman is arguing that business people
are ethical if and only if they struggle to increase
their profits and that they are entitled as part of that
struggle to do whatever the law permits. As long as
a person’s profit-maximizing actions conform to the
law and professional rules, he is, in Friedman’s view,
acting ethically.
Ethics is not rules.
The activities of businesses under the Nazi regime
should be sufficient to show that morality2 and law
are distinct. Helping to build extermination camps
was legal and good for profits but it was not ethical.
Even in a more just society, laws often state only a
minimum requirement, usually what is enforceable in
practice, rather than what is right. Yet Friedman’s
answer is the most common one in business today.
Friedman’s approach to ethics is limited because rules
cannot cover every situation. An ethical code that
simply gives detailed rules and nothing else will sink
under pressure either from clever people who find
ways round the rules or from new situations the rules
don’t cover. Another very real problem for investors
who take law as their professional moral guide is the
different laws that operate in the different countries
where they do business. While the sale of the pesticide
DDT is illegal in the EU, it is legal in many less
developed countries. Does that make it morally
acceptable to invest in factories producing DDT in
poor countries?
What distinguishes ethics from rules is that rules tell
you how to act while ethics tells you how to think
before acting. If rules are the bricks with which we
build the house that shelters us from greed and
selfishness, then the foundations of that house are
ethics. Without ethical foundations, the house of rules
will collapse under the growing weight of regulations
and the pressure of financial storms.
So what is ethics?
Put simply, ethics is the way we resolve conflicts of
desire. If I earn a thousand pounds, I want to keep it
all to buy a TV. The government wants to build a
hospital and so wants to take my money. My
neighbor also wants to take my money because he
is out of work and wants to feed his family. There are
three conflicting desires surrounding my thousand
pounds. The ethics of our culture has devised a way
of resolving this conflict: the government is entitled
to say, 25% of my money (called income tax) and I
am entitled to the 75%.My neighbor is entitled to
none of my 75% but is entitled to some of the 25%
in the form of unemployment benefit given to him
by the government. Taxation and social benefits are
not considered theft in our culture; they are
considered right and proper. Ethics has resolved the
conflict of desires and provided a basis upon which
people can then write rules to govern taxation and
social benefits.
1 Friedman, M,“ The social responsibility of business is to increase its profits.” In T. L. Beauchamp and N. E. Bowie (Eds.),
Ethical theory and business (pp. 55-60). Englewood Cliff Financial Services, NJ: Prentice-Hall, 1993
2 For the purposes of this paper, we use the terms ‘ethics’ and ‘morality’ interchangeably, whilst we accept that philosophical
distinctions can be made regarding their usage. 3

Utilitarian and other modern
ethical theories
Now the way that people resolve conflicts of desire
has gone through many different phases in history.
Within religious traditions there are moral rules
revealed by God; these are ultimate but they no
longer command general support within western
culture. So from the 18th century onwards, European
and North American society devised codes of ethics
based on rational rather than revealed values. Two
such systems carried all before them. Utilitarianism
was devised in England, firstly by Bentham, who set
out a simple principle: always acts so as to maximize
pleasure and minimize pain. This was later modified
by Mill to read: always act so as to maximize
happiness for the maximum number. The German
philosopher Kant said Utilitarianism was the
morality of pigs, simply pursuing pleasure. He
proposed instead that people should always act in
accordance with that principle or maxim by which
you want everybody to act; this universalization
principle is the rational way to know your moral
duty. Customers are often unwittingly Kantian in
their approach to providers: they insist that a
company has a duty to care for them, even though
the company will lose out by doing so.
These two ethical systems have dominated Western
culture for the last hundred years (omitting the
Marxist ethic that was so influential in Eastern
Europe, Russia and China). Ends or goals drive the
first, while the second is based on duty. Most recent
social, political and economic decisions in Western
culture have been derived from one of these two
principles. Yet both are fraught not only with
theoretical but also with practical problems. For
example, are governments morally justified in
fostering a high level of unemployment if it enables
the majority to prosper? When is a minority so large
that its unhappiness cannot be ignored, whatever the
majority may wish? Does the maximum number
include foreigners or just my own countrymen? And
who defines duty? If I am a condemned man on
death row, I want to universalize the principle of no
capital punishment; if I am the father of the victim, I
universalize the principle of an eye for an eye.
Weak rule utilitarianism
In Financial Services, utilitarianism tends to
dominate and this throws up particular variants of
the problems already highlighted. Here, as in most
areas, the utilitarian approach is not applied to
individual instances; it is applied to the creation of
rules. So, for example, rather than deciding if each
instance of insider trading is immoral by utilitarian
standards, utilitarian ethics concludes that the
maximum happiness is generated by a rule against
all insider trading. This Rule Utilitarian approach
can be applied strictly (e.g. lying is always wrong)
or weakly (e.g. lying is usually wrong but is
acceptable to save life, as when soldiers are
interrogated by an enemy).This Weak Rule
Utilitarian Approach characterizes the attitude of
Western ethical culture today.
This approach is practical and easy to understand, yet
it seems to encourage an attitude of reckless risk
taking. For example, somebody agrees with the rules
but knows that if he cheats a little at work no
noticeable harm will be done. So if he gains
£10,000 from a bank that has billions, £10,000 is a
lot to my family and nothing to the bank; therefore
the sum total of happiness is increased by utilitarian
standards. Therefore, somebody might argue, this is
not really immoral, even though it may be against
the rules. So the clever cheat becomes a hero. This
attitude may be becoming more common in society
and in Financial Services. Moreover, the perceived
growth of this attitude makes clients suspicious of
those who work in Financial Services. This paper
therefore contends that we need a new approach to
ethics if the infrastructure of Financial Services is to
withstand the attacks upon it by the professionals
who should be safeguarding it.
4
3 “After Virtue” by Alasdair Macintyre
4 The 2002 Reith Lectures “Towards Justice and Virtue” by Onora O’Neill contain an analysis of the contemporary
insistence on rights and rules, and the need for this to be counterbalanced by duty and virtue.
Virtue ethics
‘Virtue ethics’ is an approach which is rooted in
ancient Greek philosophy and which has experienced
a revival among contemporary philosophers. This
requires virtuous people to act virtuously in a virtuous
environment. This, of course, begs the question: what is
virtue? According to one contemporary philosopher3, a
virtue is an acquired human quality that enables us to
achieve those goods which are internal to the practices
that we value. This means that we do not look outside
the activity in order to maximize happiness or
universalize duty, instead we state those human qualities
needed to do the job well within the terms of the job
itself. This principle is well recognized in the medical
world: I will give my patient the best treatment
available no matter what the circumstances e.g. I may
be shunned for treating a dying terrorist by those
claiming the world is better off if he dies. In this
instance the medical profession’s own standards are
what prevail, not external considerations. We believe a
similar approach is needed in Financial Services.
Integrity: virtues and values
Many business codes of ethics insist that employees
must work with integrity without defining this
quality. We define integrity as the synthesis of the
virtues. In practice, companies speak of values and we
will use the word ‘value’ instead of the word ‘virtue’.
The core principle of integrity is thus defined as a
synthesis of values, comprising an integrated balance
of sometimes-contradictory demands. As has already
been stated, ethics is the resolution of conflicting
desires or interests and integrity is the value that
integrates all the other values. We need, then, to list
some of those values which we wish to promote and
then describe some practical examples. This will
include not only values for the individual but also for
companies and wider communities. People need to
be an integral part of something larger than
themselves, which must in itself have integrity – a
virtuous environment within which to work.
Fairness: rights and duties
A core value in contemporary society is justice or
fairness. The popular insistence on rights is an
expression of an ordinary person’s sense of fairness.
Yet to be truly fair, we believe there must be an equal
insistence on duties.4 For example, a consumer’s right
to have an insurance claim paid quickly needs to be
balanced by the consumer’s duty to tell the truth
about the real value of items damaged. Fairness is a
core feature of integrity, derived from people’s sense
of dependency, and the insight that all human beings
are inter-dependent.
A word of caution is needed about the way people use
the language of rights. To assert that there are natural
rights can lead to a belief that rights describe some
previous human condition where all was harmony and
that we all have a right to this Garden of Eden that has
been taken from us. Such is not the meaning of rights
being used here. Instead of rights as descriptive, the
meaning in Financial Services will be prescriptive. That
is to say, the sector prescribes what its employees and
consumers have a right to expect when doing business.
This will draw on a natural sense of the need for
honesty, competence and so on, but in the end, the
rights will be prescribed by the sector both through
industry regulations and through firms’ own rules.
While there is a natural, descriptive ‘right to life’, is
there a social, prescriptive ‘right to a pension’?
The answer to the question “what is business ethics”
is now clear. Business ethics will usually include as a
necessary ingredient the laws of the country where
the company operates, the exception being laws that
are in themselves unjust. But in order to be complete,
business ethics also requires a prescribed list of values,
rights and duties which are to be understood and
affirmed in the particular business under
consideration. The next section addresses how such a
prescribed list might evolve within Financial Services.
5
Integrity and fairness thus emerge as core business
principles. We contend that firms and individuals
must always place these principles above profit if
they are to be ethical.
If this statement seems challenging, then simply
consider in what situations you are prepared to
compromise these principles? Are you happy to share
these instances with your customers, employees and
investors?
Fairness in practice
Financial Services can only build an ethical foundation
if, in the same way as a profession, the members
complete a journey that leads to a personal
understanding of fairness and integrity. Only when
understanding becomes an assumption shared
throughout the organization, then they are able to
uphold the rights, duties and values that define fairness
and integrity within Financial Services.
The rights of all Financial Services stakeholders are
described in the law, particularly the FSMA, and in
FSA regulations. All Financial Services practitioners
should be aware of these and an understanding of
them is an essential part of professional training.
These laws and regulations state the minimum
expectations of standards and compliance.
Yet it is the contention of this paper that fairness may
require more than this. Practitioners have a duty to
uphold not only defined rights but also other basic
needs. For example, employers have not only a duty to
treat employees fairly but also a duty to deal fairly
with competitors. Similarly, Corporate Social
Responsibility is another way of companies
discharging their duty to the wider community. Such
duties go beyond regulation and compliance.
Integrity in practice
Integrity is often difficult to grasp in itself because it
is a synthesis of values but if we look at some core
values, the reality of integrity becomes clearer. We
can explore these values in a very simple but
powerful way, using the traditional concept of
“virtues and vices”.
According to Classical philosophers, there are four
virtues: Prudence, Fortitude, Temperance and Justice. In
contemporary business, Prudence and Justice are still
widely used and understood. Fortitude and
Temperance are more commonly called Courage and
Patience. To these, Christian philosophers added Faith,
Hope and Charity, Charity in this sense a synonym for
“Care”. These may seem unusual in a business context
but they are still very relevant. For example, do people
have faith in the meaning of their work? Are service
industries supposed to provide “customer care”? Do
employees view their career with cynicism or hope?5
To this list of traditional virtues, we wish to add
three core values that frequently appear in corporate
mission statements. These are Excellence, Honesty
and Trust. (There are many other values which can
be added to this list, for example Creativity, Humility
or Tolerance. If integrity is about understanding
shared moral values, then we believe that people
have the freedom to add other values if that helps
them to define integrity in their own personal and
working lives.)
6
3. An Ethical Foundation for
Financial Services
5 “Most strikingly, we found evidence that the majority of City workers intend to quit their careers within the next five
years.” From “Facing the Future in the City”, published by Chiumento, Spring 2003.
Some examples of values and vices
in practice
Courage: It sometimes takes great courage to
“blow the whistle”, when we see someone doing
wrong. We struggle against the cultural
perception of being a “grass” or “telling tales”. It
also requires real courage to place principle above
profit, especially if a bonus or even your job might
be at stake.8
Justice: (or Fairness): When making a
mistake, companies should not hesitate in
admitting the error, should apologize and then
make recompense. It should not have taken
politicians and the regulator to identify and rectify
the pensions mis-selling scandal. In this respect, for
example, even the automotive industry seems to
act with higher ethical standards when they
“recall” cars to rectify faults.
Care: Customer Care, Health & Safety, and
Corporate Social Responsibility are contemporary
areas where the importance of this value is
obvious. Less palatable for financial services is to
recognize and address the vices of greed and envy.
For example, regulation does not address the issue
of greed.” Fat cats”, speculative investors,
commission-driven salesmen and even consumers
can become connected in a vicious circle of greed.
Prudence: informs us that if we sell or are sold
the prospect of exceptional rewards, then we must
assume that the risk is equally exceptional. This
requires not only the salesman to communicate
this in “big print”, but also the consumer to
recognize when a proposition is reckless.
Excellence: is a value which reminds us that
“if something’s worth doing, it’s worth doing
well”. If we can apply our talents to our work
with a passion, then the quality of our work will
delight our customers. In this respect, this
principle always comes before sustainable profits.
Honesty and Trust: are values which are
obviously vital to financial services. Yet, recent and
continuing scandals have seriously eroded the
reputation of financial services. One way of
reversing this erosion, is for society to witness a
serious and convincing commitment to integrity
by everyone in the industry.
7
CLASSICAL VIRTUES CORE VALUES6 VICES7
Fortitude Courage Cowardice
Justice Justice/Fairness Injustice
Temperance Patience Anger
Prudence Recklessness
Faith Faith/Loyalty Disloyalty
Hope Hope/Initiative Despair
Charity Care Envy/Greed
Excellence Incompetence
Honesty Dishonesty
Trust Distrust
6 Adapted from Solomon, R,“A Better Way to Think About Business”, Oxford University Press, 1999
7 In conformity with the tradition of virtue ethics, our list also includes the relevant vices or deficiencies we must avoid.
8 A note on integrating values. It is difficult to imagine any one particular virtue, apart from integrity, which is
sufficient in itself to provide us with our ethical foundation. However, if we combine a number of values into an
integrative ethical framework, these apparent excesses or contradictions are balanced. For example, we need to resolve the
virtues of Loyalty vs. Courage in a whistle-blowing context.
“Integrity is the cornerstone, if not the bedrock, upon
which all financial markets are based.”
(Hank Paulson, Chairman and CEO, Goldman Sachs
Group June 2002)
Whilst we have described a number of values and
vices, this list is not exhaustive and should not imply
that integrity can be learned by heart like the “The
Ten Commandments”. We do not propose that it is
right that people should merely read a code of
ethics or a list of values and then sign a declaration
to that effect.
In the early 1970s, Harvard Professor Lawrence
Kohlberg proposed a model of Moral Development
which demonstrated that people shaped their sense of
morality through the following stages9:
1. “Obedience and Punishment” – We are children
and we behave acceptably because we are told
what to do by an authority figure such as a
parent or teacher. This obedience is enforced
by the threat or application of punishment.
2. “Individualism, Instrumentalism and
Exchange” – This is when we recognize that it is
in our best interests to be moral.
3. “Good boy/girl” – We do the right thing
because it will gain the approval of others.
4. “Law and order” – We abide by the law and
have a sense of duty.
5. “Social contract” – We have a strong sense of
social responsibility and the welfare of others.
6. “Principled Conscience” – We accept universal
principles of morality and the demands of
individual conscience.
Kohlberg believed and demonstrated that we evolve
our sense of integrity step-by-step, through moral
discussion.10 If we accept this model + the challenge
for everyone in Financial Services is to assess
honestly their personal and collective stage of moral
development!
The action we therefore propose is that every
stakeholder within the financial services industry has
a duty to seek a personal understanding of integrity
– an understanding of where they are in this journey
of moral reasoning.
Whilst the aim is challenging, the process is simple
and does not require significant resources. The
process will involve bringing together values in a
personal synthesis, through coaching or mentoring
for example; and then collectively, in a shared
affirmation of ethical behavior, through seminars or
workshops. In turn, we believe that each member
firm has both the right and duty to contribute to an
on-going industry-wide debate.11
In DP18, Sir Howard Davies, FSA Chairman, wrote
that “… our high level standards are based on ethical
values. But it is not clear that this ethos is fully
understood or applied consistently by everyone
working in the industry”. We believe that this process
must be led by the personal commitment of
Chairmen and CEOs of member firms. But we go
further than Sir Howard by contending that this
process must also include every employee and
stakeholder in the business, including shareholders,
customers and even suppliers, It’s about doing the
right thing by all stakeholders.
Integrity in practice is not about rules, tick-boxes or
codes. Integrity in practice is not just about exploring
moral values. Integrity in practice is about the
affirmation of shared moral values. This is how we can
rebuild trust and reputation in Financial Services.
8
4. Integrity in Practice
9 A Summary of Lawrence Kohlberg’s Stages of Moral Development, Barger R.N., University of Notre Dame.
10 Whilst this step-by-step approach has been challenged, this model is still widely accepted both by philosophers and
Psychologists.
11 An “Ethics Forum” has already been established under the auspices of the Skills Council for Financial Services.
9
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