A Commando Approach to Compliance: The Case for Customer Centricity

By Pauline Blondet • Wednesday, July 24, 2019

In our daily jobs, we spend most of our time trying to cope with a heavy workload, managing our team, and working with internal stakeholders. But what about taking a step back and focus on our internal clients? In this edition of A Commando Approach to Compliance, we explore just that.

After all, developing a thriving and sustainable business without happy clients is close to impossible. This applies to your company, but also to your ethics and compliance function. Getting your clients engaged will not only help you make your compliance program a success, but it will also change the positioning of compliance. From nay-sayer in the ivory tower who “does not really understand the business” to a valuable and trusted business partner.

How do we make it happen? In my opinion, it starts with being humble. We know the law, we know the risks and the processes we need to implement, but do we know what our clients need? Have we asked them to participate in the definition of the program? Have we asked them what they think?

Here are 3 simple steps to regain customer-centricity:

1. Involve operational teams in the roll-out of your program

This requires acknowledging the fact that these operational teams, who systematically involve you in the most irritating fashion at the last minute to ask for your opinion on a JV partner in a risky territory and who cause some of your late nights in the office and dinner cancellations may have valuable ideas, opinions and feedback to provide on how to manage the risks of third parties!

We need to be consistent: we cannot rant about the fact that operational teams really “don't get it” and have a bad culture if we constantly push constraining new rules on them, without notice, expecting that they will be happy about it and just do as we say.

If we want compliance to impact everyone in the company and change the culture, we should approach it differently. It starts with not being so protective about it and involving all the appropriate teams, from conception to deployment. And guess what? This may even make your program better!

Furthermore, from an effective change management perspective, involving the people you want to impact is just smart. Nobody likes to receive a new procedure which impacts their ways of working without having been notified or involved in advance. If this is the case, no wonder that they will react adversely to it.

To the contrary, anybody involved in conceiving a process or part of your program will be far more likely to support its deployment and advocate for it internally. By involving impacted teams as necessary and in due time, you will save a lot of time in implementation and jump-start internal buy-in.

This approach does not only make practical sense, but it is also what authorities require as this is the approach most likely to ensure the effective implementation of the compliance program. For example, see an extract of the U.S. Department of Justice’s Evaluation of Corporate Compliance Programs below:

“Design – What is the company’s process for designing and implementing new policies and procedures, and has that process changed over time? Who has been involved in the design of policies and procedures? Have business units been consulted prior to rolling them out?”

If you have been working differently until then, and if your relationship to the business is complex, I suggest you start your new approach by an exercise which will change the perception people may have about you, and maybe even the perception you have about yourself!

2. Ask for feedback

Don't fear the great 360 feedback round: it is rough, radical, yet invaluable feedback about the way you work and interact with the team.

It also shows your internal clients that:

You have the humility required to go through that rough exercise
You have no misplaced ego
You are willing to learn and adapt your ways of working for the greater good

Ask your HR to help you conduct the exercise. They will help you in defining a set of questions you can ask that relate to your leadership, how you interact with others, how you manage challenges, how you handle confrontation etc.

A few tips below on how to conduct the exercise:

Select a dozen peers and stakeholders, people you work with on a regular basis. Make sure to include in this list people with whom you have a hard time working with, as they will likely provide you with the most valuable feedback.
Meet with them in person to explain that you want to improve your impact and efficiency at work and that you want to start from a fair assessment of your qualities and potential for improvement. Maybe this is the opportunity to have lunch and build informal relationships that will smoothen the way you work together!
Ask if they would be willing to participate in helping you improve the way you work together.
This will put them in a positive mindset to participate in the exercise in a constructive manner.

Once the results are collected, take a deep breath, analyze them, and implement key actions to improve based on the output of such feedback to increase your impact and efficiency.

As a complement to asking your peers what they think, you may also want to ask additional parties you work with about what they think of your compliance program and related initiatives.

3. Ask the bigger crowd

Make asking for feedback part of your DNA, formally and informally. This makes you way more accessible and helps drive a culture of trust in which people feel they are heard and supported. It applies to most cases:

When you deliver in-person training: start by telling people attending that this session is dedicated to them, and should be useful to them. If it is not, the point is missed. Tell them that you will do your best to make the session useful and constructive and that if it is not the case, they should tell you. Whenever you provide a real-life example or in Q&A, ask them whether this is relevant to them. You could be surprised how much this may impact how your presentation is received by the audience. Once you are done, ask for their feedback.
When you deliver e-learning: make sure to collect examples from the business and run your draft through a few employees representative of the targeted audience before you release it to all. Don’t release your campaign without attaching a quick survey with it, asking employees what they thought of the training.
And more generally whenever you implement a new process: systematically ask people involved what they think along the way. This will keep them engaged, and your critical mind will stay alert.
Lastly, consider running a yearly engagement survey to all employees, to measure the compliance culture and the impact of your initiative, and to ask whether they think other initiatives should be carried out.

Last but not least, don’t forget to adopt a similarly engaging approach with your compliance team (you can refer to A Commando Approach to Compliance: The Secrets to Keeping Your Team Motivated for more detail).

I hope this inspires you to think about your positioning differently and to adopt a few ideas to make sure to put your internal clients at the center of the way you run your initiatives!