CCO Insights

Compliance: Staying on Message

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If you ever played the “telephone game” as a child, you know that a message may become diluted and even altered at each point where the message is re-communicated. This outcome can be funny if you are playing the game as a child, but inconsistent messaging about your compliance program is no laughing matter. How can you work towards consistent compliance program messaging across your company? Here are a few ideas:Start at the top

Tone at the top may seem like a song on repeat on this blog, but the importance of meaningful tone at the top simply cannot be overemphasized. Company leaders who not only talk the talk but also walk the walk of compliance—preferably in the normal course of business—are invaluable.

Headquarters (HQ) has at least two key roles in ensuring consistent compliance messaging. First, statements and actions by top-level company executives help set a culture of compliance (or not) throughout the company. Anytime company leaders come together, they have the opportunity to learn practices (both good and bad) from each other. As the facilitator of many of these meetings, HQ functions have an important role in helping company leaders at all levels (and in all geographies) internalize good compliance practices.

Second, the various HQ functions involved with compliance communications (e.g., compliance, human resources, sales) have the ability to coordinate, strategize, and release their communications supporting the compliance program in a way that helps all employees (and agents) hear and internalize the right messages. HQ functions have the perspective to know in which areas of the world local culture would suggest “bending rules” and can thus organize their communications (and training) to particularly target those areas. In addition, through monitoring and periodic compliance audits, the HQ-based compliance function can see where the problems with implementation lie, so that “weak links” can be addressed, through communications and otherwise, before real problems arise.

Training, training, training

Training local leaders is one way of ensuring consistent messaging around a compliance program. All individuals susceptible to compliance risks should receive appropriate training—and the training takeaways should be relatively consistent across the company. One way to ensure this is to have the same individual conduct in-person training throughout the company, but this is highly impractical for most international companies. Web-based “live” training is an alternative. Another way is to have a “train the trainer” session, where all individuals who will provide compliance training—whether they are part of the compliance function or part of local management—receive specific instructions about how to present the compliance program.

Not only does having such a group training session help ensure that everyone is on the same page, but it also gives individuals who will be conducting training an opportunity to share the questions and concerns they expect their audiences to have—and then to collectively discuss how to deal with these issues before they engage in any training. For this reason, it is best to give the “future trainers” a chance to practice how they would deal with questions and concerns that arise, for example, through role-playing exercises.

Reach across functional divides

Compliance messaging needs to be consistent, not just through the ranks, but also across company functions and divisions. For example, if one executive tells employees that the “bottom line” is the only thing that really matters, this message directly conflicts with the compliance message that “ethical business” is important.

One way to help align executives is to take advantage of times when senior leaders from across the company (compliance, operations, sales/marketing, finance, and others) are together for goals and strategy sessions. Help create opportunities for leaders from different functions to understand each other’s goals, and then promote deciding collectively what overall (compliance and other) messages should be shared with company personnel. Consider role-playing scenarios—to drive home the challenges in, and importance of, delivering consistent messaging. For example, try having a sales executive play the part of compliance officer and a compliance officer play the part of sales executive, so that they can each better understand the other’s point of view.

Check in locally

It is part of the human experience that we all see things in different ways. Two individuals may even interpret the same word differently, especially if they do not speak the same native language. The only way to truly know whether the compliance message is heard, understood, and applied consistently throughout the company is to find out what’s happening locally. Audits and compliance reviews can assist in this regard, but do not forget the value of human interaction, especially when a visit from HQ is not expected. Whether planned or not, every visit from an HQ representative—whether by compliance or by senior management—provides a chance to catch a glimpse of what is really happening “in the trenches.” Therefore, give HQ personnel visiting local offices a chance to interact collectively and individually with a variety of local staff in order to get a sense of how compliance and other important company messaging is actually being processed on the ground.

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