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Managing Culture Risk

Welcome to a special five-part blog series on building a stronger culture of compliance, sponsored by Diligent. In this series I will visit with Yvette Hollingsworth-Clark, Viktor Cuijak, Jessica Czeczuga; Michael Parker; and Alexander Cotoia. In this series, we will consider what is culture, how to assess culture, putting together a strategy to manage culture based upon this assessment, the monitoring of that strategy going forward and using information from your monitoring to engage in continuous improvement of your culture.

Many compliance professionals struggle with the ‘softness’ of culture. However, properly viewed culture can be seen as another type of risk for any organization. Viewed through this lens, culture can then be assessed, managed, monitored and improved as any other business risk. This has become even more important since the announcement in October 2021 by Deputy Attorney General Lisa Monaco, that the Department of Justice would assess corporate culture as a part of corporate compliance enforcement action. In this Part 3, we consider how to manage your culture risk through the crucial role of managers with assess your culture with Jessica Czeczuga.

Jessica Czeczuga is a seasoned professional with over two decades of experience in the training and development field, specializing in areas such as finance, quality, compliance and ethics, leadership, and communication training. Jessica brings a unique perspective to the compliance space, emphasizing the pivotal role of managers in shaping and reinforcing company culture. She believes that managers, being the most influential group within an organization, should be adequately trained to align with the desired culture and equipped with the necessary tools to effectively communicate and reinforce cultural values. Jessica also advocates for the collaboration between compliance professionals and HR to improve culture, leveraging their counseling skills and creating clear processes for reporting and addressing culture-related issues.

According to Czeczuga, managers are the most influential group in an organization when it comes to shaping company culture. They are the boots on the ground, constantly interacting with the employees that report to them. Their ability to talk and influence gives them a lot of power in driving the desired culture. Therefore, it is crucial for organizations to reach out to managers and get them on board with the desired culture, as they will naturally drive that message deeper into the organization.

She emphasized the importance of managers in shaping and reinforcing company culture was discussed. Managers play a significant role in driving the desired culture deeper into the organization, as they are in constant contact with employees and have the ability to support, promote, permit, or ignore certain behaviors and values.

To effectively manage culture, compliance professionals need to empower and train managers. Just like any other training program, a strong training program should be set up for managers, focusing not only on providing them with information about the desired culture but also on practical application. Role-playing and conversations with employees are key to driving behavior change and ensuring that managers are equipped to deliver the desired cultural messages.

The collaboration between HR and compliance departments is also important in reinforcing the importance of culture and driving a culture of reporting. HR, with its extensive touchpoints with employees, plays a crucial role in reinforcing compliance and culture messages. By partnering with HR, compliance professionals can ensure that the messages about culture are consistent and delivered from multiple angles, making them stronger and more impactful.

HR can also provide valuable insights and skills to the compliance function. HR has as many touchpoints with employees as any other corporate function, making it an ideal partner for compliance in reinforcing culture. HR can help compliance professionals in delivering messages about culture to different levels of employees and can provide guidance on how to address culture issues in conversations with employees.

The key takeaway is that managers have a crucial role in shaping and reinforcing company culture. They are the gatekeepers of culture and have the power to drive the desired culture deeper into the organization. To effectively manage culture, compliance professionals should focus on empowering and training managers, while also collaborating with HR to reinforce culture messages. Practical application, such as role-playing and conversations with employees, is key to driving behavior change and ensuring that managers are equipped to deliver the desired cultural messages.

In conclusion, the role of managers in shaping and reinforcing company culture cannot be underestimated. They have the ability to support, promote, permit, or ignore certain behaviors and values, making them the most influential group in an organization when it comes to culture. By empowering and training managers, and collaborating with HR, compliance professionals can effectively manage culture and drive the desired behaviors and values throughout the organization.

Join us tomorrow where we explore monitoring culture.

Tune into Jessica Czeczuga on the Diligent podcast series Unlocking Success: The Crucial Role of Culture in a Best Practices Compliance Program.

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Compliance Into the Weeds

Compliance into the Weeds: MGM Grand Data Breach

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent MGM Reports data breach and what it may mean for CCOs and Danny Ocean.

The MGM Grand data breach, a significant cyber-attack that disrupted MGM Resorts’ operations across the U.S., has raised serious concerns about cybersecurity and regulatory requirements. Tom and Matt discuss the potential financial impact and regulatory investigations that may arise from the breach, emphasizes the severity of the situation and the potential consequences for MGM.

They also question MGM’s disaster recovery and business continuity plans and raises concerns about the network design vulnerabilities that allowed the attack to have such a widespread impact. He also discusses the implications of the breach in relation to new SEC rules mandating the disclosure of material cybersecurity events by public companies. Join Tom Fox and Matt Kelly as they delve deeper into these issues in this episode of the Compliance into the Weeds podcast.

 Key Highlights

·      MGM Grand Cyber Attack Disrupts Operations

·      Understanding the Impact of Qualitatively Material Cybersecurity Incidents

·      Navigating Material Cybersecurity Event Disclosure Requirements

·      Inadequate backup plans leading to operational disruptions

·      MGM’s Ransomware Attack and Business Continuity

 Resources

Matt in LinkedIn

Matt on Radical Compliance

Tom 

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The Hill Country Podcast

The Hill Country Podcast – Local Kerrville Business Environment

Welcome to award-winning The Hill Country Podcast. The Texas Hill Country is one of the most beautiful places on earth. In this podcast, Hill Country resident Tom Fox visits with the people and organizations that make this the most unique areas of Texas. Join Tom as he explores the people, places and their activities of the Texas Hill Country. In this special episode, I am joined by Andrew Gay, Kenneth O’Neal and Gilbert Paiz to discuss the local business environment in Kerrville.

Gilbert Paiz is a successful entrepreneur with a background in community outreach and thought leadership. Andrew Gay is a seasoned business professional with a wealth of experience in the industry. Kenneth O’Neal is a passionate advocate for mental health and well-being in business, all share a common perspective on the importance of prioritizing mental health and well-being in business, especially amid the pandemic. Gilbert and Andrew, who started their own business believe in keeping the customer at the forefront while also caring for the mental health and well-being of their employees. Kenneth, with his extensive experience advocating for a shift in mindset towards mental health and well-being, sees the pandemic as an opportunity for businesses to change their approach and prioritize the well-being of their employees. Join Tom Fox, Gilbert, Andrew, and Kenneth on this episode of the Hill Country Podcast to delve deeper into their perspectives and experiences on prioritizing mental health and well-being in business amid the pandemic.

Key Highlights

  • Prioritizing Mental Health in the Workplace
  • Thriving Local Businesses Making a Positive Impact
  • Building a Culture of Community and Success
  • Creating a Harmonious Work Environment through Goal Alignment
  • Building a Pipeline Through Social Media
  • Embracing Challenges and Continuous Improvement
  • Embracing the Gift of Each Day

 Resources

Tom Fox

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Daily Compliance News

Daily Compliance News: September 20, 2023 – The Sins of The Parents Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in 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.

·       SEC probes Musk corporate perks.   (WSJ)

·       CBRE busted over pre-taliation. (Radical Compliance)

·       FTX sues SBF’s parents. (FT)

·       BASF fights ‘conspiracy jurisdiction’. (Reuters)

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31 Days to More Effective Compliance Programs

One Month to More Effective Written Standards: Day 12 – Policies on Charitable Donations

What should your compliance policy and procedures on charitable donations look like? What should you prohibit or even caution against? The starting point is the 2012 FCPA Guidance regarding charitable donations. The information on the red flags from the Opinion Releases and the best practices, as set out in the 2020 FCPA Resource Guide, have been available for some time. From the Schering-Plough and Lilly enforcement actions, your policy should consider the timing of charitable donations to see if they are at or near the time of the awarding of new or continued business. Finally, in managing the relationship, you now need to look at overall increases in sales to determine if they are tied to a pattern of charitable donations. By looking at the timing and quantum of charitable donations, internal audit may be able to ascertain that a spike in sales is tied to corrupt conduct.

Three key takeaways:

1.What are the basic inquiries to make around charitable donations?

2.Use all of the communication tools the DOJ has provided; written guidance, enforcement actions and Opinion Releases to inform your charitable donation policy.

3. Document, Document, and Document the basis of your charitable donations risk assessment.

For more information, check out The Compliance Handbook, 4th edition, here.

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Innovation in Compliance

Unlocking Success: The Crucial Role of Culture in Compliance: Part 3 – Jessica Czeczuga on Creating a Strategy to Manage Culture

Welcome to a special series on building a stronger culture of compliance through targeted and effective training sponsored by Diligent. I will visit with Yvette Hollingsworth-Clark, Viktor Culjak, Jessica Czeczuga, Michael Parker, and Alexander Cotoia. Over this series, we will consider what culture is, how to assess culture, putting together a strategy to manage culture based upon this assessment, monitoring that strategy in the future, and using information from your monitoring to improve your culture continuously. In Part 3, we visit with Jessica Czeczuga on how to develop a strategy to manage your culture risk.

Jessica Czeczuga is a seasoned professional with over two decades of experience in training and development, specializing in areas such as finance, quality, compliance and ethics, leadership, and communication training. Jessica brings a unique perspective to the compliance space, emphasizing the pivotal role of managers in shaping and reinforcing company culture. She believes that managers, the most influential group within an organization, should be adequately trained to align with the desired culture and equipped with the necessary tools to communicate and reinforce cultural values effectively. Jessica also advocates for collaboration between compliance professionals and HR to improve culture, leveraging their counseling skills and creating clear processes for reporting and addressing culture-related issues. Join Tom Fox and Jessica Czeczuga as we dive deeply into this topic in this Unlocking Success: The Crucial Role of Culture podcast episode.

Key Highlights: 

  • The Impact of Managers on Company Culture
  • Collaborative Partnership: HR and Compliance Driving Reporting
  • The Role of Managers in Shaping Culture

Ready for Purpose-Driven Compliance? Diligent equips leaders with the tools to build, monitor, and maintain an open, transparent ethics and compliance culture. For more information and to book a demo, visit Diligent.com.

 Join us tomorrow, where we consider how to monitor culture going forward.