When chief compliance officers take a top-down approach, they are often met with resistance — it’s just part of human nature. This dynamic can be observed in politics and the workplace, families and relationships, and it’s an ongoing issue in compliance. Whether you’re putting together a new compliance program or trying to improve or update an existing system, you won’t get anywhere by trying to do it all yourself. A successful program requires management to actively participate, not just sign off.
WHY DO-IT-YOURSELF DOESN’T WORK
An organization’s management (as well as its board or other governing body) must take a variety of actions to demonstrate leadership and commitment to the company’s compliance management program. You need buy-in from other departments to run a successful program, and also have a duty to support them in ways that not only triggers continual improvement, but promotes a corporate culture of compliance overall.
The compliance department, by nature of its functions, has to work and coordinate with the rests of the organization’s departments. Yet, this is sometimes not as straightforward as it may seem. Take for example, rolling out a compliance training session; If you go to a manager in HR and tell them what their people are going to have to do for compliance training, they aren’t going to want to work with you, unless they themselves fully realize and accept the importance of the task. Buy-in is equally crucial when it comes to the financial team. Finance handles the financial records and manage the financial controls that are fundamental to demonstrating whether or not your compliance program is working. You need timely reports from the team, but as with HR, the finance team doesn’t work for you unless you have buy-in from the finance department.
3 TIPS FOR IMPROVING PARTICIPATION
- Ask For Advice: Solicit advice from all stakeholders. Remember, it’s not enough to just get other departments to sign off. They need to feel like they’re part of the process. The finance and HR departments might be a good place to start, but don’t overlook other business units.
- Demonstrate Respect: When you sit down with other business units to discuss the compliance program, frame your questions in ways that show consideration and respect. One example might be, “I’ll need to get these reports from somebody on your team. How could we go about that in a way that’s going to be the least disruptive to your business unit?”
- Create A Working Group: Having a working group makes it easier to include stakeholders as you develop or improve your program. Gathering these people together around a table allows you to get quick feedback and ask questions, such as, “If I wanted to change this procedure, how would it affect you?” or “How could we reach this goal without holding up your department?”
These conversations are greatly appreciated by other parts of the business, and have a big impact on the success of your compliance program.
WHEN YOU SUCCEED IN GETTING MANAGEMENT ON BOARD
When management is demonstrating effective buy-in to the company’s compliance program, they are ensuring the integration of the requirements of the program into the organization’s various processes. They candidly discuss the company’s reporting procedures for suspected and actual misconduct and encourage employees to make use of these. Managers emphasize the careful handling of such reports and ensures that whistleblowers will by no means suffer retaliatory action. Effective management buy-in also means that management is committed to ensuring the independence of the compliance department and the allocation of appropriate resources to execute compliance-related operations. Management bares genuine interest in the appropriate design and functioning of the compliance program of the company and ensures that it can achieve its objectives. Management talk the talk by communicating company policies and stance on compliance both internally and externally, and walk the walk by not only conforming to the requirements of the compliance program, and by supporting other relevant management roles to demonstrate their leadership in preventing and detecting bribery as it applies to their areas of responsibility.
It may all sound simple and tangible, but achieving a symbiotic relationship between the company’s departments is challenging. Hence the crucial element of management buy-in, also known as the tone from the top. Leading the way on implementation and conformity to the company’s policies and procedures rubs off on employees, and as long as a company’s compliance culture is perceived as a process to which every party contributes to upholding, the efficiency of your compliance program becomes indeed tangible.