CCO Insights

A Commando Approach to Compliance: 3 Steps to Get Every Department Excited About Compliance

We all agree it’s so much easier to do your job when you are supported at every level of your organization, by every key function. In my last blog post, I discussed how to get your board, and more generally top management, on board with compliance. In this edition of A Commando Approach to Compliance, we want to stress 3 simple steps you should take in order to get every department excited about compliance.

Our goal is to create engagement at all levels of the organization, in every function. Making sure all stakeholders are excited will not only accelerate the cultural impact of ethics & compliance, but it will also effectively complement the work you are doing daily to engage top management.

Indeed, it is so much easier to pitch to your boss or board when they have heard the same drill over and over again from other functions. So today, we dig into the 3 secrets of horizontal influence within your organization. How do you make sure other functions not only support you but actually adopt your priorities as their priorities?

1. Put Your Foot in Every Door (And Don’t Get it Smashed)

Every department head should know you and like you.

Make sure to have lunch or coffee at least once a week with one of these heads. You want them to have you on their radars. During these informal meetings, offer your services to help talk about compliance to their teams (and then rock the event of course). For example, presenting during annual internal control sessions or sales seminars are great times to discuss compliance.

No global functional seminar shall take place without you, your team, or champions speaking about compliance.

Why seminars? It’s the perfect gathering of a given functional team globally in one place, and your chance to see them in person.

Make sure to be present and speak at every event and to make it an enjoyable moment for all. To do that with success, you need to make it fun in order to get your peers excited about compliance. Let’s face it: nobody wants to invite a grey lawyer who will bore their teams out. You want to have an impact, right? Make it useful to them. Drop the sleepy masterclass and instead create workshops and serious games which actively engage participants. The fact that we are discussing competition law or anti-corruption doesn’t mean that we should not spend a good moment together.

The grapevine will do its magic and I promise that in no time, you will become a highly demanded seminar superstar.

You may think that you don’t have time for relationship building and doing the “easy” compliance communication while you have so much on your plate. Let me tell you that this is time well spent. If people like you as a person and if you make them shine in their own events, I promise you that more complicated conversations about not engaging with a potential business partner will be much smoother!

2. Know Your Playing Field: Map Your Stakeholders

To do the above effectively, take one hour to map your stakeholders. You need to know who you face, and what you need from them in order to build a plan to impact them properly.

Below is a suggestion of how stakeholders and departments can be classified, make sure to adapt it to your organization:

Stakeholder Who They Are What You Need from Them How to Get It
The Top The Board, your boss, committees, Executive Committee, anybody with decision making power in your company. Support, resources and for them to lead by example. Pick your battles, be concise and present very clear and highly contrasting options to choose from. To know more, please refer to my last blog post: A Commando Approach to Compliance: Get your board on board.
Your Champions Members of your team, but also members of your broader E&C network, as well as key champions that you have identified among operational functions.

More generally all employees empowered by compliance, be it a full-time or a part-time job for them.

Your champions help you multiply your message and cascade it throughout your organization. They are key to unifying communication about compliance and to impact the culture. You want to make sure they not only get the message right but relay it appropriately as often as they can. Be extremely clear about the key messages you want them to pass along within the organization.

They should all be able to pitch compliance and its value: train them on the key messages and prepare cheat sheets. Then relax and imagine the sweet payoff of your voice and message repeating itself until engraved in your organization’s DNA.

Gatekeepers in Other Support Functions Functions from which you need concrete actions in order to deploy your compliance framework, such as HR, internal control and audit, finance, but also investigations, legal, risk, etc.

Furthermore, by being particularly sensitized to risks and issues, they are extremely helpful to keep you posted on risks or processes that are not followed.

You need them to help you deploy your initiatives. You cannot fully deploy your governance or impact the incentive system without HR. You need legal to make sure your compliance clause is included in contracts. You need internal control and audit to deploy the internal control referential you have prepared in every entity. You need the audit plan to match your risk map. You need to work closely with them to make sure your priorities are their priorities.

Meet with each head of these functions on a monthly basis to be clear about what you to work together on and keep momentum on delivery.

Create a compliance task force where you meet regularly altogether.

Discuss your respective yearly objectives and make sure they align on key points.

Operational Functions You Need To Impact With Processes All the teams whose processes should be impacted by compliance.

Teams considered risky based on your risk matrix.

Sales, procurement, operations etc.

Implement compliance processes and culture in their operations. Make sure to know the leaders of every functional team.

Have a bottom-up approach when you are preparing a new process that will impact them: it is so much harder to oppose something you have contributed to. Test your process with a pilot to gather feedback.

Once your process is set, train all impacted teams as relevant: there is no way your third party management process is going to be a success if sales are not involved and supportive.

In training them, establish super users by taking the most engaged team member to follow up with the team and be your point of contact.

Make sure to keep track of all you do and measure the engagement of every campaign to adapt and improve over time.

All Other Employees All employees that do not belong to the prior categories. Be engaged and advocates of your company culture. More generally, don’t forget to reach all employees with high-quality compliance content. You want everybody to be part of the culture, irrespective of their level of risk exposure.

Run a yearly survey to measure their compliance savviness and engagement level.

Depending on the size of your organization,  compliance software could help you boost your outreach effectively.

3. Deliver Your Message Like a Communications Pro

We know you are busy, or even super busy, with matters of such high importance that sometimes you can’t sleep at night, and therefore you may think that communication is trivial.

Let me put it bluntly: not communicating on what you are doing because you are too busy is shooting yourself in the foot. If you don’t communicate broadly at all levels of your organization, how can you expect to impact the culture and get support when you ask for it? Who would fund a project that they have never heard of and don’t understand the importance of?

Communication, according to Merriam Webster is “a process by which information is exchanged between individuals through a common system of symbols, signs, or behavior”, but also  “personal rapport”.

Communication serves a dual purpose:

  • Making you shine and revealing your impact to the broader organization
  • Helping you develop personal relationships with people, which, as we saw above, will help you when you need to discuss tough cases.

Back to basics. Let’s keep it simple and effective. All you need is a plan. In the same way, you build a multi-year strategic ethics & compliance plan, think about building and maintaining a communication plan for your department.

You’re not a communication expert? No biggie, I’m not either. Building a communication plan is a lot of common sense. It is “a step by step process to ensure that the intended message is received, understood, and acted upon by the recipient,” according to Business Dictionary.

A communication plan involves:

  • Determining the objectives
  • Choosing the audience
  • Selecting the appropriate channel(s) to reach them

Build on the above stakeholder map, pick your objectives per quarter, which stakeholders you want to reach, then decide on the media and resources needed. You want to present in person at the Executive Committee, while you may want to reach the entire company with posters and a super fun video about ethics. A communication plan thus allows you to organize and allocate your resources wisely in a structured manner.

Lastly, your communication plan can be used as a reporting tool to update top management on your progress and measure your impact on culture along the way.

I hope that by following the three steps I laid out above, you too will be able to multiply your efforts by getting your entire organization excited about compliance!

A Commando Approach to Compliance

In case you didn’t catch the introductory post, Key Compliance Challenges from the Field: Meet GAN’s Newest 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 will focus 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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