A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is about creating a distinctive brand philosophy of compliance which is centered on your consumers. In other words, it helps a compliance practitioner to anticipate all the aspects of your employees needs around compliance. This is especially true when compliance is either perceived as something that comes out of the home office or is perceived as the “Land of No.” A 360-degree view of compliance gives you the opportunity to build a new brand image for your compliance program. This is important as the Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance) mandates that for a compliance program to be effective, it must be understood by a wide variety of stakeholders.
Communications is often thought of as a two-way street – upward and downward, inbound and outbound, or side-to-side. However, it is better to think of it as a 360-degree effort. You simply can no longer effectively communicate in just two ways. You now communicate in a more holistic manner, and in multiple ways. If you are just thinking about communications in the classic form, you are missing something that is happening around you.
360-degrees of compliance communication is not just a classic form of communication but rather it is a communication in the concept of every interaction, whether they be planned or accidental interactions. It is all a form of communication. This is particularly true if you are a compliance professional, practitioner or Chief Compliance Officer. The things you do, the way you act, and the way people see you, you are always communicating. It is not simply communicating one to one as often you may be communicating to a group across siloed boundaries, to the constituencies you had not even planned to communicate with initially.
Three key takeaways:
- Remember the definition of 360-degrees of communication. It is an effort that moves the compliance identity into a holistic approach so compliance is in touch and visible to your employees at all times.
- What is your objective? What are you trying to do with your 360-degrees of communications and how are you using that mechanism to deliver the objectives of your compliance program?
- Evaluate. You need to evaluate three factors: 1) has the message been delivered; 2) has it been heard; and 3) is it being implemented?