Seifert Submits ‘Code of Ethics’

NEW YORK In an 18-page code of ethics submitted to U.S. District Court Judge Richard M. Berman yesterday, former Ogilvy & Mather executive Shona Seifert warns ad agencies that “government policies and practices are extremely complex … Don’t take a government contract if your agency is not well versed in all the regulations.”

The document is part of the sentence Berman levied in July after concluding that “a slippage in ethics” was at the heart of a scheme masterminded by Seifert and co-defendant Thomas Early to overbill the White House’s Office of National Drug Control Policy for marketing services.

Seifert in her code also noted that “ethics can’t be imposed upon the advertising industry. They need to be understood and internalized by all of us.”

The document quotes former General Electric CEO Jack Welch, Dwight D. Eisenhower and Woody Allen, among others.

In the document, Seifert also said the industry faces some unique ethics challenges in part because “the advertising industry places a higher value on big ideas than we do on process.”

She continued, “However accurately we capture our time and costs, it isn’t going to build a brand or help create famous advertising. So timekeeping and cost controls tend to be delegated and managers focus on ‘bigger issues.’ Until the timekeeping and cost controls are a bigger issue.”

She also said, “Boring work has never resulted in a prison sentence. Poor timekeeping practices have.”

Seifert was sentenced to 18 months imprisonment for her role in a scheme to overbill the government’s $1 billion ONDCP account to cover a $3 million revenue shortfall on the business [Adweek Online, July 14].

Seifert was also ordered to pay a $125,000 fine and a $1,000 special assessment, in addition to writing her “code of ethics” for the ad industry as part of 400 hours of community service.

Berman levied a harsher sentence on Seifert than on Early, who received 14 months in jail, in part because of her role as a hands-on manager. “Because of [the staff’s] trust and respect for Ms. Seifert, they made the changes [on timesheets] … and put themselves in legal and ethical jeopardy,” Berman said during the sentencing hearing.

Seifert addressed a boss’ responsibilities in a passage that reads, “Managers have a special responsibility to encourage ethical behavior and set the example for others.” To underlings, she advised, “Don’t be an order taker … If you believe something is wrong, you have a responsibility to say so, regardless of your position in the company or the industry.”

Seifert will surrender on or before Sept. 6 and likely serve her sentence at a minimum security facility in Danbury, Conn.

In addition to his sentence, Early, Ogilvy’s former finance director, must pay $11,000 in fines and fees. He will surrender on Sept. 21 and serve his sentence at a facility in Pennsylvania.

Early and Seifert, a former executive group director at the agency, in February were found guilty of all 10 counts against them: one for conspiring to defraud the government and the rest for filing false claims.

Each faced up to five years in prison.

During testimony at the trial, the defendants insisted they did not ask Ogilvy employees to doctor timesheets to fraudulently increase the number of hours billed to the ONDCP. Early did concede that some timesheets appeared to contain inaccuracies.

Seifert for two years had been president of Omnicom Group’s TBWA\Chiat\Day in New York. She took a three-month leave from the agency starting on Jan. 1 to prepare for the trial. Seifert and TBWA\C\D severed ties on Feb. 28.