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31 Days to More Effective Compliance Programs

The Role of HR in Creating an Ethical Culture


The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done at multiple levels. The 2019 Guidance also called out culture as a key indicia for an ethical culture. Creating an ethical culture is an important step for any company to burn compliance into the DNA of a business. It must be done at every level of an organization on a continuous basis. Human Resources (HR) can play a key role in both the creation and maintenance of an ethical culture.
Ethics and compliance blend together in the corporate world. It is not just the responsibility of CCOs and compliance practitioners but of HR to support those employees who want to do the right thing. While written protocols are significant in both detection and prevention, one should never lose sight of a corporate culture as a way to positively impact your workforce and company going forward.
Three key takeaways:

  1. Beware of the three obstacles to creating an ethical culture.
  2. What really matters in your company?
  3. A speak up culture will improve the operational performance of your business.
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12 O’Clock High-a podcast on business leadership

Business Leadership Failures from 2019-Boeing


This week I have a special five-part podcast series where I am joined by Amii Barnard-Bahn to review some of the top business leadership failures of 2019.  Today, we take a look at leadership failures from the continuing saga of Boeing. Some of the issues we explore in this podcast include:

  • This case is a tragic ethical failure, which caused significant loss of life.
  • Boeing clearly has a broken culture. There is low trust, lack of accountability between employees and management, coupled with unhealthy cultural norms at work.
  • What has been the role of the FAA? Has there been questionable regulatory oversight?
  • Boeing has a brand new CEO but the entire company needs total turnaround. 

About Amii
 Amii Barnard-Bahn, JD, PCC, CCEP, CCEP-I  is an executive coach who specializes in accelerating the success of legal and compliance executives and their teams. A leadership columnist for Compliance Week and Fellow at the Harvard Institute of Coaching, Amii previously shaped company culture and strategic initiatives as an executive (CAO, Chief Compliance Officer, and Chief Human Resources Officer) at companies such as McKesson and Allianz. Forbes has recognized Amii as “one of the top coaches for legal and compliance executives.”  
Contact Amii
Executive Coach and Strategic Advisor
Barnard-Bahn Coaching & Consulting
Office: (510) 301-0400 | Email: amii@barnardbahn.com |website: www.barnardbahn.com
Resources
For helpful insights and actionable tips on accelerating your career, sign up for Amii’s bi-monthly newsletter at bit.ly/amiibbnews

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Innovation in Compliance

Putting Compliance In Your Hands with Garin Bergman


This week’s guest on Innovation In Compliance is Garin Bergman, founder of the Palmtree compliance app. He chats with Tom Fox and Ronnie Feldman about the app, and how it puts compliance into the hands of employees.

Making Compliance Simpler and Timely
Ronnie believes that the next boundary in compliance is simplicity, not complexity. Garin’s innovative solution is a simple way to get compliance to people through technology, he says. Garin explains that Palmtree is a mobile application for smartphones and tablets that allows compliance departments to put their materials into their employees’ hands wherever they are. The app can recognize employees’ location and send them communications that might be relevant to their project or that might minimize compliance risk. In addition, having the app available on their devices – an environment they’re already used to and like to use – in an engaging and easy to read format, further supports the compliance program.
Key Features
Palmtree has the ability to track and analyze metrics that are important to the company. Another innovative feature is the gift registry module. Garin explains that this allows individuals to submit gifts to be reviewed and approved by their supervisor. The supervisor is notified of the request and, using the information available in the app, makes an informed decision whether to allow the gift. The request is approved or declined right within the app, and the employee is notified. Additionally, robust back end analytics can provide reports on the types of gifts that have been given over the past two years.
Solving A Compliance Problem
Tom comments that an often overlooked reason why adoption of new technology is slow in the compliance industry is that it requires lawyers, who comprise the majority of the industry, to deviate from the static policies, procedures and delivery of training they’re accustomed to using.
People also assume that having a solution like Palmtree will be very expensive, Garin says. However, the cost is quite reasonable and it can be deployed in as few as 45 to 60 days. Tom adds that it also allows you to comply with the Department of Justice’s requirements for ongoing improvement of your compliance program.
Resources
Garin Bergman
LinkedIn Profile
PalmTree Website
Ronnie Feldman
Ronnie Feldman (LinkedIn) | Twitter
Learnings & Entertainments (LinkedIn) 
Learnings & Entertainments (Website)
60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.
Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.
Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.

Categories
Daily Compliance News

February 4, 2020, the Farewell to a Telecom Cowboy edition


In today’s edition of Daily Compliance News:

  • Bernie Ebbers dies. (NPR)
  • What was the culture at L Brands-make a compliant, you get fired. (NYT)
  • Keep your pants on at work (Part 31,297). (WSJ)
  • Airbus to have monitor. (WSJ)