It’s a tricky thing to understand what a high-performing compliance program actually looks like. Aside from activities and checklists and even anonymous tips, a high-performing compliance program must include the human element. Do we, as a company, believe we’re always doing the right thing? Because in the end, that is what compliance is all about.
We’ve been fortunate to work with and have at MCO some of the most respected leaders in the compliance space. And from them, we’ve crafted a few best practices for high-performing compliance programs that everyone can easily put into place.
Best Practice 1 – Create a good, strong, and ethical culture
A recent survey of compliance professionals found that 40% wanted to ensure that their compliance programs had strong levels of trust and respect and no retaliation for those who do report suspected compliance violations. Looking more deeply into cultural diagnostics of the business is well worth any investment one might make. Do employees feel good about the culture of the company? If they do, chances are they will always do the right thing.
Best Practice 2 – Create – and continue – employee focus groups
Focus groups have always been a foundation of any good product roll-out, simply because the business is getting honest feedback to see if a product will actually sell. It’s the same with corporate compliance programs. A high-performing compliance program will always appreciate the truth, no matter how uncomfortable it might be. The best time to conduct focus groups is after an in-depth employee survey because the business can see if there are any hot spots to address around trust, respect, transparency or decision-making levels. The groups can go deeper into these hot spots to help craft actions that will help the company – and employees – to always do the right thing.
Best Practice 3 – Training, training, training
Training is always a key element of any compliance program, and not surprisingly, something that even government oversight agencies talk about in depth. In fact, the most recent Department of Justice (DOJ) guidelines phrase training “Is the training in the form and language appropriate for the intended audience?” Keep in mind many employees these days are not native English speakers, and some may not have sophisticated levels of education. Knowing this helps to craft language that is straightforward and accessible to everyone. The good thing about the advances in employee training is that research shows that training tailored to specific topics in bite-sized chunks is far more accepted by employees. What’s more, these bite-sized chunks of training help employees retain the information longer and remember to always do the right thing.
A high-performing compliance program will always appreciate the truth, no matter how uncomfortable it might be.
Best Practice 4 – Get the right communications medium for the right audience
One of the biggest things that has been learned about communication over the years is to make sure that businesses are tailoring the right message for the person they intend to receive it. Very simply, create communications for very specific tasks or roles / responsibilities. Make it easy for people to know it’s there and make it easy to comply. People who approve invoices for third parties will not be interested in compliance procedures for people who review expense reports. This sounds very common sense, but it is the little details that make for a high-performing compliance program and helping employees to always do the right thing.
Best Practice 5 – Operationalize the compliance program
This is easier said than done. But if the business focuses on where it can make the most impact, it will succeed. One example is to operationalize where the employees may not be the people who are completely knowledgeable about anti-bribery, intellectual property, or conflicts of interest. So, it can pay off in terms of the impact to give these employees the tools they need to help the company be ethical and compliant.
Remember, high-performing compliance programs are geared toward changing the mindset and inspiring the commitment to ethical behavior.
Want to know more about creating a high-performing compliance program? Give us a shout; we’re expecting you.
