You need a good Compliance Officer: To run ethics and compliance campaign
INTEGRITY BEAT - Henry J. Schumacher (The Freeman) - December 7, 2018 - 12:00am

New regulatory concerns, ethics issues, or business objectives arise all the time in the corporate world, where senior executives want the compliance department to help deliver a new message about corporate conduct.

Savvy compliance officers know what that means: a new ethics and compliance campaign to develop and roll out.

Run a smartly planned campaign, and the organization can see measurable results and reduced risk. Rush a campaign out the door thoughtlessly, and you’ve squandered resources — and your credibility as a compliance officer.

So what best practices in campaign rollout should you remember? Here are a few:

Keep the message focused

A campaign to launch a new compliance program is different from a campaign to encourage a speak-up culture; which is different from a campaign to cease working with questionable intermediaries; and so forth.

Compliance officers need to understand the objective the campaign should achieve, and then consider what messaging works best to achieve it. For example, a campaign encouraging a speak-up culture might rely primarily on awareness: posters in the breakroom, notices given out with the hotline phone number, and the like. You simply want employees to know that speaking up about misconduct is OK.

A campaign telling employees to avoid unsavory third parties would be more complex because you’re asking them to do something. They will need to know why they are taking that action, and what specific steps they should take. So you might begin with a message from the CEO or head of sales about the importance of ethical business practice, followed up with employee certifications of a new policy, supplemented with training.

Marshal the right executive support

Sure, having the CEO plug your new compliance campaign is nice, but the CEO isn’t necessarily the coworker that most employees will heed closely, because most employees don’t interact with the CEO closely — and cynical employees dismissing “more of the same” from management is the kiss of death for any compliance campaign.

So consider which fairly senior executives carry weight with the workforce, and recruit them to the cause. In our example above about third parties, we mentioned the CEO or the head of sales giving a talk. Most sales employees work with the head of sales more than the CEO. They listen to her or him more closely. The point of a compliance campaign is to make a difference in workforce behavior, so whichever executives exert the most influence with your audience — win them over to your cause. You’ll need them.

Ask the employees to do something

Any marketing guru will tell you that a good campaign ends with a “call to action” — attend this event, download this paper, donate to this charity, contact this official. The ‘call to action’ is clear, prominent, and asks the recipient to participate.

Compliance campaigns are no different. A call to action involves the employee in the compliance process, which is the whole goal: to have employees embrace and participate in ethics and compliance, rather than wait for the compliance department “to do compliance” and go away.

So ask employees: “call the hotline when you see something wrong,” “don’t pay bribes,” “think twice before you make that comment.” Convey that request through posters, email, training courses, executive speeches, and whatever else — but ask them.

Give employees a voice

A good compliance campaign (and a good compliance program overall) should include feedback channels. Partly that’s to accommodate the calls to action described above; people might take the action, after all. More broadly, if the goal of a campaign is to build interest in working with compliance, employees need an easy way to communicate with you. Feedback channels do that.

Certainly one permanent channel can be a hotline. Quick-hit campaigns can have feedback channels, too: a Q&A session at the end of a talk; a social media campaign with a specific hashtag; even a “meet the compliance officer!” hangout in the conference room would count.

Compliance – whether we like it or not – is playing a growing role in the way we do business. We need to be aware that if we encounter compliance breaches, from data privacy to cyber security, from paying bribes to participating in cartels, the reputation of our organization is put on the line. That’s why I am advocating the engagement of a good Compliance Officer. Your feedback is welcome – you can email me at Schumacher@eitsc.com

ETHICS
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