We are back with another five episodes of Adventures in Compliance to consider the next five stories from The Casebook of Sherlock Holmes, mining each story for themes and lessons related to the compliance professional, leadership and business ethics. In today’s offering, I consider The Three Garridebs. From this story the need for objective discipline in a variety of areas in any best practices compliance program.
- That objectivity in disciple is called the Fair Process Doctrine. As you incorporate the Fair Process Doctrine in your compliance program, there are three key areas to focus on.
- Administration of discipline.Discipline must not only be administered fairly but it must be administered uniformly across the company for the violation of any compliance policy.
- Employee promotions.If your company is seen to advance and only reward employees who achieve their numbers by whatever means necessary, other employees will certainly take note and it will be understood what management evaluates and rewards employees on.
- Internal investigations. Simply put, if your employees do not believe that the investigation is fair and impartial, then it is not fair and impartial.
- An often-overlooked role of any Chief Compliance Officer (CCO) or compliance professional is to help provide employees with procedural fairness. If your compliance function is seen to be fair in the way it treats employees, in areas as varied as financial incentives, to promotions, to uniform discipline meted out across the globe; employees are more likely to inform the compliance department when something goes array. If employees believe they will be treated fairly, it will go a long way to more fully operationalizing your compliance program.