We’ve improved our ethical screening policy

Written by Tom Greenwood - February 7, 2024

Since the very early days of Wholegrain, we’ve tried to screen the projects that we work on to ensure that they align with our own values. It’s always seemed like a no-brainer to me that if you’re being paid for services to help other organisations achieve their goals, then those goals should not contradict your own ethics or objectives. Even better, they should align with your own ethics so that you are truly pulling in the same direction as your clients.

In the early days, Vineeta and I did this screening of projects intuitively. As co-founders it was relatively easy to decide what felt right to us, but we gradually rubbed up against the ambiguity of this approach. We realised that having a written policy would make it easier to make tough decisions and to explain those decisions to other people, especially to our colleagues and the people who we occasionally decide to turn down as clients. And so we wrote a policy that, barring a few little tweaks, has lasted us until for most of Wholegrain’s existence until now.

How did it work?

The ethical screening policy divided all new leads into three categories as follows:

  • Green – Projects or organisations with a positive social or environmental mission 
  • Red – The usual suspects of fossil fuels, tobacco, gambling, animal agriculture, armaments and a few others
  • Grey – everything in between

We would prioritise leads in the green category and turn down anything in the red category, even if we needed the money. Anything in the grey category was reviewed on a case by case basis. Simple.

This policy has stood the test of time because it’s simple and because it honestly reflects our values. That doesn’t mean that it’s been easy though.

Implementing the screening policy has been extremely challenging at times, especially when we had to turn down people who we really liked, or when we really couldn’t afford to turn down the work. Those moments of tension are when a policy like this really gets put to the test and I’m proud that we’ve stuck with it even through hard (and awkward) situations. 

We’ve gained a fair bit of experience in navigating those tricky situations and I wrote an article on ‘Having the guts to say no to bad money’ a few years ago in which I shared a lot about the challenges of ethical screening and how we try to approach it. I’ve come to believe that taking the hard path has helped us develop an inner strength as a company as well as a reputation of integrity that has served us well over the long term. As my friend Russ Stoddard says,

“Values aren’t worth anything unless they cost you something”

So what’s this article really about? 

Well, last year we took on some work that some people in our team felt we shouldn’t have done. It led to some fascinating (and at times heated) debate, and highlighted that while the process we’ve had in place all these years has been simple and mostly effective, it can’t always account for the complexities of the real world. 

As a result of this challenging situation, I promised that we would update the screening policy to help prevent similar stressful situations, and that I would write about the reasons for doing so. So here we are… 

What went wrong?

It all started when we had an enquiry from an organisation who were interested in our digital sustainability consulting services to help them green their web presence. They had already read my book, Sustainable Web Design, and seemed genuinely passionate about doing the right thing, wanting to tie digital sustainability in with their wider objectives to be a leader in sustainable practices within their region. They would also be hosting a major global event and hoped to use it as a chance to showcase these best practices to a wider audience.

This seemed like a good opportunity for a number of reasons. It was an opportunity to develop our digital sustainability services with an engaged client, to raise awareness of best practices to a wider audience and potentially also do some really fun and interesting work. What’s more, there was a lot of economic uncertainty in our sector last year and this project would provide some important revenue to keep us in a financially healthy position. 

So far, so good.

However, when we got to the point of having essentially agreed the initial work with the client, some team members raised concerns about the client’s organisation having a shadow hanging over it that if true would make them feel uncomfortable working on it. We had to make a choice. Do we upset the client and miss out on the opportunity to do some really impactful work? Or do we trust the client and put the new concerns to one side?

A small group of our team got together to review the information available and decided to go ahead with the initial phase of work that had been agreed but not to do any more beyond that. In effect it was a soft rejection, which was a logical compromise but didn’t feel good. 

One thing that we could all agree on was that we didn’t want to find ourselves in such a situation again. It’s sometimes said that progress only happens under pressure, and the pressure of this situation led to us deciding that it was time to update our ethical screening policy.

Then things got really grey

Focusing our attention on the ethical screening process also put a lens on some of its other shortcomings, such as the fact that the “Grey” category is inherently ambiguous. Even more ambiguous is the fact that a client could technically be in both the Green and Red categories simultaneously. This seemed to be one of the issues with the example described above, and soon after we got another.

The enquiry was from a charity associated with one of our Red list sectors but also doing good work helping people in need. Those of us in the early stages of the sales process were stumped so we put it out to our team for a vote.

The results were:

  • 36% in favour of working on it
  • 36% against working on it
  • 29% not sure

To add to the ambiguity, we received comments anonymously from a number of team members explaining why they had voted the way they did. The arguments in favour of the project and those against it seemed equally valid. This wasn’t the first time that a team vote simply confirmed the dilemma rather than providing a solution.

It also highlighted that we didn’t have a clear mechanism to resolve a conundrum like this and that one of the challenges of our long standing ethical screening policy was that it was a policy, not a process. We therefore needed to update the policy so that it included a process of how to apply it.

Our new ethical screening policy (and process)

Our new ethical screening policy is now available to read in full in our team handbook, and the main structure is the same as the earlier policy with new leads being categorised as GREEN, GREY or RED. However, we’ve made the following key changes to minimise ambiguity and tensions in the future:

  1. Responsibility for leading the ethical screening now sits clearly with the person handling the lead.
  2. It is now a step by step process instead of just a written policy, so it can be followed methodically.
  3. We have simplified our list of RED categories and moved anything ambiguous into the GREY category.
  4. The GREY category now has a defined set of criteria that we should look for to identify whether further investigation is needed. This includes new items such as checking if the client organisation is based in a country that is listed as an authoritarian or hybrid authoritarian regime in the Democracy Index, has a past record of being accused of poor social or environmental practices or presents a mix of activities that are close to both RED and GREEN.
  5. If there is sufficient information, then the lead will be recategorised as GREEN or RED by a majority vote of the Senior Leadership Team. If there is not sufficient information, additional research will be undertaken. The decision is final and will only be reopened if needed when bidding for new contracts.
  6. Following these steps, if no significant issues are identified then a lead shall be deemed GREEN and proceed.
Flow diagram showing the steps of the screening process as described in the article

Note that in the past, the GREEN category represented a wish list of the type of projects we wanted to work on, whereas now it simply means that the lead passed the screening criteria. Prioritisation of dream clients and projects will now take place separately from the ethical screening itself.

We’ve been testing this updated policy over the past few months and have already turned down several leads as a result, so it seems to be helping reduce ambiguity without adding a significant overhead of time. Although the aspect of a team vote has now been removed, team input is still encouraged to help continually improve the policy so that it delivers the outcomes that we all want. We believe that ultimately this will be more efficient and effective than the prior system which (often unsuccessfully) attempted to resolve ambiguity by adding more people to the conversation.

Maximising positive impact

As a final thought, I believe that the most important thing is simply that we have an ethical screening policy.

If we want to be a responsible and sustainable business then we cannot simply look inwards at the direct impacts we are having in our day to day operations, but must look up and out at the wider impact that our work is having in society. Clients pay us for our expertise because we help them to achieve their objectives, and so we cannot shrug off responsibility for the role we play in helping them.

Furthermore, when we successfully align our own values with those of the client, it means that we are truly pulling in the same direction and can achieve much greater things together as a combined team. Hence a strong screening policy is about much more than just avoiding involvement in negative impacts, but also about maximising our positive impact in collaboration with our clients.