Welcome to a special five-part podcast series on Operationalizing Your Compliance Program, sponsored by Broadcat LLC. Over this series, I visit with Jennifer May, Director of Compliance Advisory; Taylor Edwards, Director of Sales; Xinia Pirkey, Design Manager; Alex Klingelberger, Chief Executive Officer (CEO) and Jaycee Dempsey, Director of Customer Success. We consider a variety of ways to more fully operationalize your compliance regime, including the design and effectiveness of your communications, why the operationalization of compliance is a team sport, why simply data is not the answer and how to avoid being overwhelmed. In Part 3, I am joined by Jaycee Dempsey to discuss operationalizing your compliance program through employee engagement and participation.
We began with break down what operationalizing compliance. Dempsey said it’s “making compliance training not something that is done on a one-time basis, on a routine basis like once a year, but rather something that is integrated into the day-to-day work for all your employees. It means that you are training them on what they actually are doing that creates or mitigates risk versus compliance concepts generally.”
From there she had the most interesting insight that compliance at its most basic is a “team sport.” As a compliance professional or even compliance function “you can’t be everywhere at once, nor should you be. You need to engage your employees. You have to speak the language of the business, because that’s what gets you the seat at the table.” She also believes that business executives have an important role to play as their “attitude towards compliance trickles down to the rest of the organization and that your employees are looking up to them. If your leadership is not talking about ethics and compliance regularly, it will affect the entire culture of the organization no matter what you’re trying to do in the compliance team.” This means you “need to have them on board and they also need reminding of their role in operationalizing compliance.”
As important as your senior leaders are and their role in compliance, Dempsey believes middle managers “may be even more impactful than your C-Suite.” As a compliance practitioner you must make “sure that you’re reaching out to them as well.” But once again it is giving middle managers the tools, training and communications to be effective as the first point of contact for many employees who wish to speak up and raise a concern.
But in addition to being an initial point of contact for employees who want to speak up, middle managers are the folks that are engaging day-to-day with their teams. Middle managers make decisions on raises, promotions, what projects their people are on. A middle manager is often the position that is the next step in an employee’s career ladder. This means that employees are “paying very close attention to the way that their manager acts, the things that they say and the way that they think up.” Dempsey had the insight that “middle managers are a living, breathing, real life example of what the organization promotes, no matter what’s said on paper.” This means that in many ways “they’re also key to operationalizing compliance.”
Many compliance professional do not think of our employees as customers. Dempsey believes a compliance function should do so “because essentially your role is like an internal marketing agency. You’re trying to influence behavior.” It is also about “making actual meaningful change in the way that people do their jobs, while making sure that you are reducing risk.” This means a compliance function should be focused on “delivering guidance at that moment when they need it with very concrete steps, be in a position you can provide them with information on what you need to do to be successful in your position.”
Another insight Dempsey had from marketing is the term “seven different ways, seven different times.” This is not simply “copying and pasting the same message over and over.” It is “thinking through the different ways that you can message your employees what is available to you.” It can be a variety of strategies and tactics. It can be internal social media, “utilizing those flat panels that are in break rooms, in front of elevators or near the cafeteria or simply pushing out screensavers on everyone’s computer, with those quick reminders or a desktop shortcut to your reporting hotline.” It can also be more old school such as “emails from the compliance team from leaders and your middle managers.” Finally, “embedding checklists and decision trees and into your processes and making sure that you’re providing toolkits to your managers and leaders for discussion-based training is a key for documentation.”
Join us in Part 4 where we look at effectiveness, redux.
For more information go to TheBroadcat.com
