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Changing the Compliance Tone

By Matt Kelly

The good news: more and more companies do take compliance seriously. The bad news: some still don’t.

So if you find yourself at a company in the latter camp, the time may come when you’ll need to change the compliance tone at your organization — to elevate it; to show employees and third parties alike that compliance is a serious commitment.

Sounds great. How do you do it?

First, consider when to change the compliance tone of your organization. Some circumstances lend themselves to change more than others. The arrival of a new chief executive, new corporate owners, or even your own arrival as a new chief compliance officer: they are all perfect opportunities to bring in a “new attitude” about compliance. You can also take advantage of expanding into new markets, striking a joint venture or even resolving a regulatory investigation.

Whenever the time is right, there’s still the question of what actions to take. Which ones deliver the most impact to get people’s attention, and what else should happen to show stakeholders the change in tone is real?

Slogans and branding help, but only so much

When trying to elevate the importance of compliance or to shift the perceptions people have (say, moving from the “Department of No” stigma to more “Do the Right Thing”) — yes, clever branding will help. One of my favorites is a compliance officer who hands out toothbrushes to employees emblazoned with “make compliance part of your daily routine.” Simple messages asking people to embrace compliance are crucial.

Still, employees can smell a slogan with no substance behind it from miles away. For them to take compliance seriously, the compliance function needs to follow up with real changes to policy and procedure. Which brings us to…

Consider what holds people’s attention

That’s not the same as what gets people’s attention. For example, disciplinary action against an employee for misconduct can get other employees’ attention for a moment — but then the moment passes. Or worse, other employees might take the lesson that they shouldn’t get caught the same way the first person did.

On the other hand, what changes to policy and procedure can hold the attention of employees and third parties — day after day, despite any other changing circumstances? Tying compensation policies to ethics and compliance is one place to start. More centralized procurement processes, to reduce the opportunity for unethical intermediaries to creep into your enterprise, are another. So is an elevation of the compliance officer into the executive management committee, where he or she can influence budgets, priorities, and policies for other departments.

Empower people

You only change the tone; they keep it. If a compliance officer wants to lead, then you need to build an environment where others want to follow. That is wholly different than a compliance officer imposing policy because he or she can force the issue.

The crucial issue here isn’t simply how to change the compliance tone at your organization; it’s how to change the tone in a positive way — so that working ethically, and working with compliance, is something others want to do.

The good news is that most people want to be ethical in their jobs and look for ways to do so. That’s not always easy in our highly regulated, highly interdependent world, but the desire is there. So if compliance officers think hard about the right gestures to make, the right messages to repeat, the right actions to take; all to leverage that innate desire into tangible progress for better compliance — that tone can cut through an awful lot of noise.

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