Last week, we talked about the fundamental questions you must ask yourself as a compliance manager or Chief Compliance Officer (CCO), to stay ahead of not just the basic inqueries from the exec team and board, but also your Plan itself. Our mantra bears repeating for step two: “compliance exists to support the business; the business does not exist to support compliance”. To this end, you must be informed - and the best information comes from the people within your organization.
Step 2: Collaborate
This is not about gathering your inner circle and confidants together for a creative project; this is about getting that group together that will produce a solid Plan. For example, consider:
- Who will add subject matter expertise?
- Who will add energy and drive to the process?
- Who will directly or indirectly (through their boss or department) add the necessary political weight?
- Who will be a good sounding board for the draft Plan on substantive or general company questions or possible red flags?
- Who do we need to have – because not having them involved would be problematic downstream?
- Should there be one group or committee to design, implement and monitor the Plan for a set period, or should the group’s remit extend to Plan design alone, with the CCO managing the remaining Plan-related task
Collaboration at senior levels may also be necessary or desirable. Consider whether you need formal approval – because of the Plan’s size, resource commitment, length and/or other possible factors – and who needs to give that authorization.
And even if formal approval is not required, query whether this is an opportunity to be seized to raise compliance visibility and engagement with senior management.
This type of voluntary collaboration with senior management can be used to underscore your business approach to the Plan exercise, and could pay dividends downstream.
With feedback from trusted colleagues, you have structured your approach so that it already has internal buy-in from key players. You've also made sure that your training plan has validation and is checked for any oversights by the right people. Now comes the fun part: You have to start producing it. We'll cover this next week in step three.
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