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A Commando Approach to Compliance: How to Partner with Key Functions to Build an Effective Compliance Program

By Pauline Blondet (Updated )

In this edition of A Commando Approach to Compliance, we provide you with key tips on how to partner with other functions in your organization to maximize the effectiveness of your compliance program.

Do you sometimes feel alone as a compliance officer? Let me tell you that you are not.

First, you belong to a really strong and active community of compliance officers who support each other and maximize their impact by sharing their experience on what works well and what does not. Feel free to tap into the deep knowledge of the community as you need. Whenever you want to try something new, you can exchange with a compliance professional who has tried it already, and that way maximize the effectiveness of your compliance program!

Second, you are not alone in your organization. No matter how small your team may be, if you feel alone, it’s time to get other functions involved and engaged.

I know you are busy, but involving other functions consistently will enable you to maximize your impact tremendously, so it is time extremely well spent.

Take a step back, make a game plan

We are all short on time, so we want to use it wisely. It is therefore crucial that you start by putting together a game plan that is realistic and effective for your organization.

First, refer to your strategic plan, and think of all the high-level quarterly results that you want to achieve this year. Your strategic plan should be accompanied by a communication plan, including stakeholder engagement (for more on how to build and deploy your communication plan, read A Commando Approach to Compliance: 3 Steps to Get Every Department Excited About Compliance).

Let’s focus on stakeholder engagement, and how to build these relationships and partnerships that will enhance the effectiveness of your compliance program. To prepare your stakeholder engagement plan, draw a simple yet effective table and list the following:

  • Each key function you want to impact in your organization
  • What you need from them to maximize the effectiveness of your compliance program
  • How connected this function is to your function already
  • Who is the decision maker in this function, who are the key influencers and/or opinion leaders
  • The importance of this partnership to the success of your ethics and compliance (E&C) program
  • Key actions needed to establish a close partnership with the identified key functions and achieve your objectives

Generally, you need to work closely with each function you pick to make sure your priorities are their priorities. Meet with the head of each of these functions on a monthly basis to be clear about the areas of collaboration and align on deliverables. Create an ethics and compliance task force where you meet regularly. Discuss your respective yearly objectives and make sure they align.

Please see below for an example with HR as Internal Control / Internal Audit functions:

Key FunctionWhat do you need from them?How connected is E&C to this function already?Who is the decision maker/key influencers?How critical is this partnership to the success of your E&C initiatives?What are the key actions needed in this partnership to achieve objectives and timeline?
HRComplete buy-in, as a member of your core team.

Draft and review your code of conduct.

Ensure your ethics hotline is well communicated.

Deploy training and policies.

Ensure clear communication across the organization.

Effective enforcement of sanctions when needed.
Not enough.

Only meeting when needed (during investigation and sanctions, for example).
Name the key persons responsible for the function. Also include key influencers within the department.Highly CriticalSet-up monthly catch-ups with the leader of the function
Introduce your objectives and ensure alignment.

Pitch your corporate compliance program to the core HR team.

Involve HR in your compliance committee.

Create an ethics and compliance task force in which HR plays a key role.

Get in front of the key influences within HR to ensure they are well trained on the benefits of compliance, what they need to do and the value to them.
Internal Control
Audit Team
Key to ensure that your processes become an integral part of the organizational set up.

You need them to have visibility, and play a gate-keeper role.

Ensure that E&C process points are included in internal audit referentials.

Be a gatekeeper ahead.

They typically have a strong network across the organization, with close ties to representatives in every single entity.
Quite well.

E&C is invited to seminars, several trainings are provided.

We review the audit framework together.
Name the key persons responsible for the function and the key influences within the department.CriticalInclude the leaders of these functions in your compliance committee.

Create an ethics and compliance task force in which they play a key role.

Train their members further and enable them to be strong gatekeepers.

Get a speaking slot at their seminars to address one key initiative each time.
All Other Business Functions (make a separate line per function)Embed compliance in their processes.Not enough.Name the key influencers.Highly CriticalMake sure to establish rapport with the leaders of every functional team.

Have a bottom-up approach when you are preparing a new process that will impact each of these functions: it is so much harder to push back on something you have contributed to. Test your process with a pilot program and gather feedback.
Once your process is defined, train all impacted teams as relevant: During the training sessions, identify super users - usually the most engaged team members - invite them to follow up with their respective teams and be your point of contact.

Make sure to keep track of all your activities and measure engagement of every campaign to adapt and improve over time.

Now that you have your game plan, prioritize your list of actions items for each quarter. Once you know exactly what you need to achieve you will need to start engaging with the identified departments. Here are a few concrete tips on how to get started.

Engage concretely key functions to maximize the effectiveness of your compliance program

  • Have lunch, be nice: this is self-evident, but sometimes overlooked. As the world reopens, safely take advantage of in-person meetings to get to know your audience, what they like, what challenges they face in their own functions, and most importantly how you can help them. Take this opportunity to share your challenges in return.
  • Pitch your ethics and compliance program to your organization: you need to be ready at all times to pitch your initiatives. Make sure your pitch sounds exciting and strategic so that people will want to be part of your program and contribute to creating a strong culture of integrity. Wonder how you create that much excitement? First you need to be excited yourself. You can also review A Commando Approach to Compliance: Master the Compliance Elevator Pitch for more guidance.
  • Create common objectives: nothing is as effective as delivering the good old quarterly objectives together as part of a collaborative project. If you both agree to include “create a new audit framework related to a given new process” in your respective objectives for the quarter, it is very likely that it will be prioritized and achieved by both your teams!
  • Involve all relevant stakeholders in the creation of your processes: There is nothing worse or more ineffective than following a process that does not meet your needs. From conception level, make sure to involve all stakeholders, collect their needs, revert back, explain choices made, and make them feel that they are an active part of the process. You know it, it will make your process so much more on point, and adoption much easier.
  • Ask for feedback in making your ethics and compliance program more effective : Generally, the key to engaging people and functions in an organization is to ask for feedback. We don't operate in a vacuum, hence ensuring we collaborate well is key to our success as an organization, as well as the success of your program. For more ideas on how to master the process of asking for feedback, you can read A Commando Approach to Compliance: How to Listen to Compliance Feedback.
    • When you gather or are given feedback about parts of your corporate compliance program, ask the person to be involved in helping you improve that part. This further strengthens constructive collaboration and further engages teams in helping you build the compliance program.
  • Sustain your partnerships over time: ensure all your efforts constitute a series of repeatable steps, creating networks and connexions all across the organization. Establish a cadence of standing monthly meetings and committees to nurture the relationships you’ve built.
  • Make sure to get invited to other functions’ events in your organization: get an invite to all events hosted by other functions. Make sure they add ethics and compliance points to their agenda, so that you can together preach about the importance of doing the right thing, and hence maximize the effectiveness of your compliance program. It’s a win-win situation. Start with the gatekeeping partners: Internal control, HR, finance, as they have a great network which will in turn give you a head start to your program.

A Commando Approach to Compliance

I hope these ideas will convince you to invest your valuable time in building relationships with stakeholders across your organization!
In case you didn’t catch the introductory post, Key Compliance Challenges from the Field: Meet GAN’s Expert, I wanted to fill you in on what ‘A Commando Approach to Compliance’ is all about.

In short: it is a blog series that focuses on the very concrete challenges compliance officers face in their day-to-day lives. The commando aspect of this title refers to the diligent and proactive approach that I believe drives the best results for compliance leaders. This blog series aims to address some of the most common but least addressed hurdles that compliance professionals strive to overcome. Sign up for our newsletter to ensure you are up to date on the latest commando blog posts!

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