In July 2020, we published the positions we hold on certain issues. In his post introducing them, Ben explained that these help us navigate who we work with.

The first of these positions says:

Public purpose defines us and our work. We want to do work that benefits the world and improves lives. We’re not interested in projects that are simply about selling more unsustainable goods, or for the financial benefit of a small number of already-wealthy individuals. We want to work on things that matter, because they help ordinary people.

But what counts as work with a public purpose? And who decides?

Over 2 years ago, we set up an ethics and risk screening process for potential new business. We also set up an Ethics Review panel to make decisions on the most complex cases.

It took us a while to formulate an approach that felt right. We looked at how other organisations handle difficult ethical decisions. We looked at our responsibilities under the UN Guiding Principles on Business and Human Rights. We collated lists of questions, criteria, and data sources that might help.

Our aims have always been to:

• Keep the decision process lightweight and proportionate to the size of our business and to the opportunity.

• Be transparent with Public Digital colleagues about our decisions and how we make them.

• Make it meaningful. There is understandably a lot of cynicism of corporate ethics boards that lack real teeth, and of ESG “greenwashing”.

We’ve been trialling and iterating our approach since then, and we feel it is now the right time to share what we’ve learned. We hope this helps peer organisations grappling with similar situations. We also hope this will provide more transparency to our potential clients and partner organisations as well as our colleagues.

Here are 5 things we’ve learned so far:

1. Our responsibility is to assess the proposed work, not the client. Our job isn't to pass judgement on the whole client organisation. No organisation is perfect. Some are operating in much more challenging conditions than others. We need to understand the work in context. For instance, we are unlikely to work for an oil company under most circumstances. But if that oil company has new leadership and wants our help as part of a shift to renewables, that’s worth careful consideration.

2. Public Digital’s decision won’t always reflect our own personal positions. That’s okay. But we do want to make sure that everyone understands and can explain why Public Digital has agreed – or refused – to take on a particular piece of work. We also give our colleagues the opportunity to opt out of working on something they are morally opposed to.

3. We must pay for our principles. So far, we’ve held Ethics review meetings for 17 potential projects and decided against going ahead with 6. We’ve said no to several autocratic regimes. We’ve said no to a company with a history of animal rights abuses. We’ve said no to an energy company focused on fossil fuels. Turning down these opportunities sometimes meant foregoing significant revenue.

4. Ethics isn’t a one-off. Ethical issues can and will arise in the course of our engagements, especially large, complex transformation programmes. We strive to carve out time during our engagements to actively anticipate and address new ethics questions.

5. We won’t always get it right. The world is messy and complex: there are few clear-cut cases. But we are trying to make and record our decisions openly, and with integrity. We follow a consistent process.

There are 2 elements of our approach:

1. Questions that act as a guide when assessing a potential piece of work. We have different questions for public sector and for private sector clients.

2. Ethics Review meetings to discuss and decide on more contentious cases.

Our Ethics Review questions for public sector clients:

1. How democratic is the country? This matters, because building digital capability in authoritarian regimes carries a risk that we will inadvertently enhance the state’s capacity to silence dissent, for example, or to systematically exclude minority groups. No single index is perfect, but we look at assessments by Freedom House and the World Justice Project’s Rule of Law Index. We also note if there is a positive trend, or if freedoms are being eroded over time.

2. Can Public Digital operate there safely and effectively? Doing business in conflict-affected areas generally involves greater risks of human rights violations. As a relatively small organisation, we don’t always have the capabilities to assist countries in conflict with confidence. And we need to be sure we can keep our own people safe. We look at the Council on Foreign Relations’ Global Conflict Tracker. We do our own research and ask trusted partner organisations for their assessment.

3. Does the work have – or contribute to – a clear public purpose? Is the client committed to using our expertise to improve people’s lives? These questions are the most difficult, and the most subjective. We have found that context really matters.

Our Ethics Review questions for private sector clients:

1. Does the organisation operate responsibly? We want to work with organisations that value and encourage diversity, and look after employee wellbeing. We strive to work with organisations that are using digital transformation to make progress on climate action. We look at companies’ ESG score, how it is trending, and how it compares with the rest of their sector. (We know ESG scores aren’t perfect, so we don’t look at these in isolation).

2. Does the work have – or contribute to – a clear public purpose? We look at what outcomes or impact is the work trying to achieve, and how it connects with users (both customers and colleagues). Would we be proud of this work? Would the work help an important company to operate more responsibly, for instance by enabling it to better respond to climate change? Or to reach underserved customers?

3. Is the client open to new ways of working? We want to work with organisations that are building their capability and are committed to adopting the right structures, ways of working and culture to deliver their mission. We look for evidence of leadership empowering teams. We look at if the company has a focus on customer outcomes and developing a deep understanding of user needs. We especially want to work with clients who demonstrate a willingness to work in the open.

The Ethics Review meetings

We hold Ethics Review meetings when it feels difficult to make a decision on whether or not to move forward with a new business opportunity. Meetings are chaired by either Emily or Lara, and are always attended by the Chair of Public Digital’s Board, Tim. Tim has experience leading international businesses and as a non-exec, he brings independent challenge. Another member of staff is a core attendee on a rotating basis – right now that’s Philippa.

The meetings are also attended by the colleague who is responsible for the potential opportunity. Wherever we have a team member with lived experience of the organisation or country context, we make sure we hear from them. The meetings are open to any colleague who wants to observe or give their opinion: we typically have at least 10 attendees, and on occasion it’s been more than 20.

Decisions and the rationale behind them are communicated to everyone internally.

Good decision-making is everyone’s responsibility

We are committed to making sure that we continue to question our decisions around new business. This is why everyone is encouraged to speak up if they have an ethical concern about a potential client. Ethics is covered as part of our new joiner induction programme – along with our Code of Conduct – and support is on hand to talk through complex situations.

We’re still learning, and are interested in how peer organisations are making similar decisions. Email contact@public.digital if you’d like to chat.