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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Introduction

In this month’s offering of 31 Days to a More Effective Compliance Program, you will learn about training and communication techniques that the CCO can use to provide a well-rounded role as a CCO and facilitate a much more holistic approach to compliance in your organization. Best of all, the techniques discussed are available at little to no cost. You can do things in your method of running the CCO positions and innovations that you can bring to the compliance function in your organization.

A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is always in touch with and visible to your employees. It is about creating a distinctive brand philosophy of compliance centered on the customers of your compliance program (i.e., your employees). It helps to anticipate all the aspects of your employee’s needs around compliance, especially when compliance is perceived as new, something that comes out of the home office, or as the Land of No. It allows you to build a new brand image for your compliance program.

The objective is to build trust for the 360-degree process by determining if the goal was achieved. You can utilize surveys or focus groups to assess the impact on your target audience. Focusing on your customers of compliance allows you to identify gaps and improve the communication process for your compliance program.

Three key takeaways:

  1. Remember the definition of 360 degrees of compliance communications. It is an effort that moves the compliance identity into a holistic approach so compliance is always in touch and visible to your employees.
  2. What is your objective? What are you trying to do with your 360-degree view of compliance communications, and how are you using that mechanism to deliver the objective your compliance program desires?
  3. You need to evaluate if the message has been delivered, has been heard, and is being implemented.

For more information, check The Compliance Handbook, 3rd Edition, available here.

Categories
Career Can D0

Overcoming Fear and Taking Action with Irene Riad

Do you ever feel like you’re not sure what your passion is? Irene Riad, an EQ and ICF certified coach, believes that finding your authentic self is the key to finding your passion in your career. In this episode of Career Can Do with host Mary Ann Faremouth, Irene shares how we can become stronger in our careers by using the wisdom of our life’s significant setbacks. She also discusses her unique seven-step renewal process, and how it can help you lead with power in your career.

When we face setbacks, we are wounded, but that wound ultimately saves us, Irene says. It teaches us how strong we can be moving forward. “It heals by actually taking small action that when you look at the wound, it just has become something that has lifted you further, allowed you to do something with more depth,” she tells Mary Ann. She helps her clients understand that they are not broken, even when faced with setbacks.

 

Irene’s seven-step RENEWAL process is a powerful tool. These steps include recognizing the voice within you, engaging with safety and choice, and leading towards your bigger picture. She also sees life as a mosaic made up of different pieces from our life experiences. She and Mary Ann agree that by looking within ourselves first, we can find our passion and lead with power. Mary Ann comments, “I think [that] we have to look within ourselves first. We have to love what we’ve experienced, really become our best selves, to be able to make the biggest contribution in our career, to be able to lead with power in a way that is going to best for us, [and] make a valuable contribution to the world.”

 

In the job search process, it’s as important to regulate your emotions as it is to send out your CV. Irene suggests that not being attached to an outcome frees you up to find better opportunities. It’s also important to “befriend” your fear, Irene tells Mary Ann.  She encourages listeners to be open to new experiences and take action, even if it feels uncomfortable, in order to find better opportunities. Don’t be afraid to take on new roles, even if they are not necessarily what you are looking for in the long term. Taking a job and gaining experience can help you understand yourself better and may lead to other opportunities. 

 

Resources

Irene Riad on the web | LinkedIn 

Faremouth.com 

 

Categories
Corruption, Crime and Compliance

Making a Culture of Ethics and Compliance a Reality

Corporate culture is the most valuable intangible asset that a company owns. In this week’s episode of Corruption, Crime and Compliance, Michael Volkov discusses the importance of corporate culture for ethics and compliance programs. He emphasizes the need for business leaders to understand the significance of corporate culture on the ground level and outlines steps and tasks needed to build and maintain a positive culture.

You’ll hear Michael discuss:

  • Corporate culture is an embodiment of a company’s values and interactions with key stakeholders. Every company has a distinct culture that defines its purpose and motivations.
  • Senior leadership plays a critical role in embedding the culture and enforcing the message. Managers and employees take their cues from corporate leaders.
  • Companies have to hold leaders accountable for wrongdoing or failure to supervise. Leaders who promote ethical cultures should be rewarded, while those who engage in misconduct should suffer discipline up to termination and recoupment of financial benefits.
  • Transparency and publicizing corporate rewards and discipline are crucial to building trust, increasing employee engagement, and promoting a positive culture. A company’s most significant reflection of its culture is employee perception and rates of misconduct.
  • CCOs have to redefine their media tasks and responsibilities to reflect the emphasis on corporate culture. They have to define specific ways to measure a company’s culture, regularly report on these measures, and monitor indicators of culture misconduct, reporting issues, financial concerns, and HR issues.
  • Monitoring, intervention, and remediation require a real-time focus and constant questioning of trends, interventions, and measurement of results. 
  • Working collaboratively with HR, legal, and finance can bring about real culture improvements with a joint mission focused on ethics and compliance.

 

KEY QUOTES

“Your corporate culture, your culture of ethics and compliance is your best control. It’s your most effective and most important control, and it’s your most valuable intangible asset.” – Michael Volkov

 

“A robust reporting system with active participation is a positive, not a negative, reflection of a company’s culture.” – Michael Volkov

 

“Companies that wait for a scandal to occur before acting have failed to do their job. Proactive compliance means prevention and focusing on your company’s culture.” – Michael Volkov

 

Resources:

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group

Categories
Daily Compliance News

May 1, 2023 – The Corporate Rot Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Stories we are following in today’s edition:

  • Bringing new tech solutions to compliance. (WSJ)
  • ChatGPT is back in Italy. (WSJ)
  • US to allow auction of CITGO. (Reuters)
  • Spotting corporate rot. (FT)

Categories
Compliance Week Conference Podcast

Joy Hayes on Using Mentorships to Navigate a Career in Compliance

In this episode of the Compliance Week 2023 Speaker Preview Podcasts series, Joy Hayes discusses some of her panel at Compliance Week 2023, “Mentorships Turned Partnerships: Navigating the Compliance Road Hand-in-Hand.”

Some of the issues she will discuss in her presentations are:

  • Women talking about their experiences, lessons, and learnings from two-way mentor/mentee relationships;
  • Steps needed to build these trusted partnerships, benefitting both parties as they navigated their professional careers; and
  • Stories of how women’s support of each other impacted both of their professional development journeys, with takeaways on how you can cultivate and invest in similar types of relationships

I hope you can join me at Compliance Week 2023. This year’s event will be May 15-17 at the JW Marriott in Washington, DC. The line-up of this year’s event is simply first-rate, with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 18th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. And many others to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders, and ethics and compliance visionaries.
  • Hear from 75+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from the two SEC Commissioners, gain insights into the agency’s enforcement areas, and walk away with guidance on remaining compliant within emerging areas such as ESG disclosure, third-party risk management, cybersecurity, cryptocurrency, and more.
  • Bring actionable takeaways from your program from various session types, including ESG, Human Trafficking, Board obligations, and many others, for you to listen, learn and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

I hope you can join me at the event. For information on the event, click here. Listeners of this podcast will receive a discount of $200 by using code TF200 on the link here.

Categories
FCPA Compliance Report

FCPA Compliance Report – Adrienne Bellehumeur on The 24-Hour Rule: Mastering Dynamic Documentation

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Join Tom Fox, the host of FCPA Compliance Report, as he speaks with Adrienne Bellehumeur, a consultant specializing in business analysis, audit, internal control programs, and effective documentation. In this episode of the FCPA Compliance Report, they discuss the secrets to smarter organizations and the importance of the 24-hour rule for documenting and retaining information. Adrienne, author of “The 24-Hour Rule,” provides practical and comprehensive techniques for dynamic documentation and pushes individuals and organizations forward through a six-step process. The discussion also covers the challenges of managing information in communication tools like Slack and WhatsApp and the need for clear repositories for future value and legal purposes. Take advantage of this informative episode and get your hands on Adrienne’s book now!

Key Highlights:

· The 24-Hour Rule: Importance of Documentation

· Dynamic documentation for managers and directors

· Mastering Successful Documentation: The Six Steps

· Effective Documentation and Data Governance

· Effective Information Management in Communication Tools

Notable Quotes:

“The 24-hour rule is what I think is the golden rule of documentation, and it’s very simple.”

“All documentation should drive back to actually pushing you personally or your organization or your team forward into a forward state to take forward action.”

“Documentation is about, and I actually believe, it’s a problem-solving technique.”

“My book is effectively a framework for better documentation where companies can assess where they’re at, look through what they have, look at I have standards I’ve developed as well.”

Resources

Adrienne Bellehumeur on LinkedIn

The 24-Hour Rule

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Principled Podcast

Principled Podcast – S9E12 – Why Arca Continental Leads with Values Over Rules in its Multinational E&C Program

What you’ll learn on this podcast episode

When it comes to driving ethical behavior in organizations, many ethics and compliance programs are beginning to focus more on leveraging company values than relying primarily on rules. But what does taking a values-based approach look like in practice, especially if you’re a multinational organization? How do talk about it with a wide range of employee populations? In this episode of LRN’s Principled Podcast, Susan Divers is joined by Gabriela Del Castillo, the chief ethics and compliance officer at Arca Continental, to discuss the importance of creating a respectful workplace and the role that E&C plays in developing ethical culture. 

Guest: Gabriela Del Castillo

Gabriela Del Castillo – Grayscale

Gabriela Del Castillo is the global chief ethics and compliance officer of Arca Continental, the second-largest Coca-Cola bottler in Latin America—and one of the largest in the world. She leads the construction of the company’s corporate sustainability through the management of ethical and compliance risks. In addition, she designs mitigation strategies—including policies, controls, and procedures—as well as communication and training initiatives for Arca’s ethics and compliance program. Gabriela also serves as the secretary of the Audit and Corporate Practices Committee for the organization’s board of directors. 

Prior to joining Arca, Gabriela was the regulatory affairs corporate manager at the food and beverage services company Empresas Polar. In this role, she helped the organization adopt risk management and compliance processes to anticipate risks and opportunities in the regulatory and legal fields. She also designed strategies to minimize costs or capture savings, based on a deep understanding of the company’s operations and stakeholders. Before that, Gabriela worked as a legal analyst for Siderúrgica del Orinoco, C.A. SIDOR, a Venezuelan steel corporation. 

Gabriela earned a master’s degree in international legal studies from Georgetown University and graduated magna cum laude from Universidad Central de Venezuela. She also received a marketing and innovation diploma from Instituto de Estudios Superiores de Administración IESA in 2017. 

Host: Susan Divers

Headshot_Susan_Divers_S7E18_Principled_Podcast

Susan Divers is a senior advisor with LRN Corporation. In that capacity, Ms. Divers brings her 30+ years’ accomplishments and experience in the ethics and compliance area to LRN partners and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance and substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance.

Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program.

Mrs. Divers’ background includes more than thirty years’ experience practicing law in these areas. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.

Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008.

She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics. Mrs. Divers’ most recent publication is “Balancing Best Practices and Reality in Compliance,” published by Compliance Week in February 2015. In her spare time, she mentors veteran and university students and enjoys outdoor activities.