How One of America’s Fastest-Growing Private Companies Launched an Ethics & Compliance Program Based on Values, not Rules

Pacific Dental Services® (PDS®), one of the leading dental support organizations in the U.S., has been growing rapidly in recent years, adding 80 supported offices per year. Michael Williamson, the company’s Chief Compliance Officer, recognized the responsibility that came with such rapid growth, and knew that it was time the company create a formal ethics and compliance program. He also felt strongly that the traditional approach to compliance – lists of rules and preventative, check-the-box measures – didn’t fit with who PDS is as a company. Instead, he wanted the program to reflect and support PDS’ strong mission and values. When he reached out to LRN, seeking a partner to help PDS build its program, we knew we had found a kindred spirit.

"The assessment was through, and the data was displayed clearly and in the voice of our people. In combination with our founder's humility and willingness to digest, accept, and address the findings, the impact was enormous. That couldn't have happened without the LRN process." — Michael Williamson, Chief Compliance Officer and Senior Director of Compliance & Ethics, PDS

PDS already had strong foundation in its organizational values, known as their “We Believes.” And so, LRN set out to help PDS envision a values-based approach to ethics and compliance based on the We Believes. The result? We helped them build an engaging ethics and compliance strategy that inspires values-based behavior while providing a shield against misconduct and driving long-term, sustainable growth. Here are four steps we took together to help them get there.


1. Understand the current state. We reviewed PDS’ existing governance system, culture and leadership, and synthesized the data from various sources to create an in-depth organizational profile. This comprehensive undertaking was conducted via:

  • One-on-one interviews
  • Focus groups
  • Organization-wide survey

The assessment reinforced the importance of the We Believes to the organization – they were a strong recruiting differentiator a source of pride for employees. However, the assessment also revealed a sense that the We Believes were being “diluted” as the organization grew.

2. Build a values-based framework. Armed with powerful insights from the assessment, our next step was to help PDS align around a shared understanding of the We Believes. The resulting We Believes Behavioral Framework clarified each value by describing behaviors that demonstrate the We Believes in action.

Key to the Framework’s success and relevance was the co-creative process through which it was developed. We engaged team members at all levels in articulating the behaviors that bring the “We Believes” to life, emphasizing those behaviors that could be applicable to ALL team members, regardless of role, location, or scope of influence. In so doing, the Framework reflects the experience and “voice” of PDS team members

3. Launch, teach and share the framework. The rollout strategy included:

  • Facilitated discussions with a focus on internalizing the Framework by contextualizing the We Believes and associated behaviors to each person’s role. 
  • Experiential learning workshops emphasizing a train-the-trainer approach where leaders go through the experience first.
  • An inspirational video featuring leaders at all levels talking about what the We Believes mean to them that is now integrated into PDS’ onboarding process for new hires. 

The power of the workshops is in creating a safe space where all PDS team members can talk about how the We Believes show up – or should show up – in their individual roles and, even more importantly, where and why it’s hard to live them. Team members can then support each other in developing strategies to overcome these barriers and demonstrate the We Believes more consistently.



Watch PDS leaders talk about the importance of the We Believes, their drive to be a higher-ambition organization, and why these values are discussed during daily team huddles.

4. Supplement and sustain the Framework. LRN developed a custom online course on the We Believes Behavioral Framework that will be rolled out to all team members as an additional learning touchpoint, providing a refresher and reinforcement of the experiential learning workshops.



PDS has made great strides toward its goal of establishing a sustainable, values-based ethics and compliance program. Still, the work necessary to align and embed values throughout the organization and its people is an ongoing process. Deep, meaningful change takes time, and LRN is honored to be a partner with PDS on this long-term journey. 

"[LRN's] authenticity cannot be overstated. Their guidance, solutions, and partnership truly reflect their spirit, and their ability to flex and accommodate the nuances of a privately held, 24-year-old organization never wavered." — Michael Williamson, Chief Compliance Officer and Senior Director of Compliance & Ethics, PDS

We are so proud of the We Believes Behavioral Framework, co-created with PDS and its employees.