A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is about creating a distinctive brand philosophy of compliance centered on your consumers. In other words, it helps a compliance practitioner to anticipate all the aspects of your employee’s needs around compliance.
This is especially true when compliance is perceived as something that comes out of the home office or as the “Land of No.” A 360-degree view of compliance allows you to build a new brand image for your compliance program. This is important as the 2020 Update mandates that for a compliance program to be effective, it must be understood by various stakeholders.
Communication is often thought of as a two-way street, upward and downward, inbound and outbound, or side-to-side. However, it is better to think of it as a 360-degree effort. You can no longer effectively communicate in just two ways. You now communicate in a more holistic manner and multiple ways. If you are thinking about communications in the classic form, you are missing something happening around you.
360 degrees of compliance communication is not just a classic form of communication but communication in every interaction, whether planned or accidental. It is all a form of communication.
This is particularly true if you are a compliance professional, practitioner, or CCO. The things you do, the way you act, and the way people see you, you are always communicating. It is not simply communicating one-to-one as often you may be communicating to a group across siloed boundaries, to the constituencies you had not even planned to communicate with initially. It also allows you to see and hear new ideas, concepts, or ways to create a more effective compliance regime for your front-line BD folks and your first line of defense.
Three key takeaways:
1. Remember the definition of 360 degrees of communication. It is an effort that moves the compliance identity into a holistic approach, so compliance is in touch and visible to your employees at all times
2. What is your objective? What are you trying to do with your 360 degrees of communications, and how are you using that mechanism to deliver the objectives of your compliance program?
3. Evaluate. You need to evaluate three factors: 1) has the message been delivered, 2) has it been heard, and 3) is it being implemented?
