In today’s edition of Sunday Book Review:
One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance program; and to create and foster a culture of compliance. While it seems axiomatic that compliance training is a mainstay of any best practices compliance program, the conversation around training has evolved over the years. The 2012 FCPA Guidance started the conversation.
Beginning in the fall of 2016, through the announcement of the FCPA Enforcement Pilot Program, the DOJ began to talk about whether you have determined the effectiveness of your training. This conversation continued with the 2017 Evaluation where it asked, “How has the company measured the effectiveness of the training?” This point has bedeviled many compliance professionals yet is now a key metric for the government in evaluating compliance training. It evolved further in the 2019 Guidance with the mandate that training must be “truly effective”. Finally, the training must be presented in a language in which the employees understand, which means in a local language, if the training is outside the US or other non-English-speaking countries.
Also raised in the 2017 Evaluation was the focus of your training programs, where the DOJ inquired into whether your training was “tailored” for the audience. This added two requirements. The first was to assess your employees for risk to determine the type of training you might need to deliver by risk ranking your employees. Obviously, the sales force would be the highest risk but there may be others who are deserving of high-risk training as well. From this risk ranking, you were required to develop tailored training for the risks those employees will face.
The 2019 Guidance spells this out in greater detail. Not only in the design but who receives it, all coupled with backend determination of effectiveness. Finally, all of this must be documented.
Three key takeaways:
In today’s edition of Daily Compliance News:
What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/customers are your employees. Social media presents some excellent mechanisms to communicate the message of compliance going forward. Many of the applications that we use in our personal communications are free or available at very low cost. Why not take advantage of them and use those same communication tools in your internal compliance marketing efforts going forward?
Why should you do so? Start with the tech-savvy nature of the today’s workforce. It is not simply about having a younger workforce but a workforce whose primary tool for communication is social media. If your company is in the services business, it probably means your employee base is using technological tools to deliver business solutions. Finally, consider the data-driven nature of business today so using technological tools to deliver products and solutions is something your company most probably does now.
Finally, never forget the social part of social media. Social media is a more holistic, multiple-sided communication. Not only are you setting out expectations but also these tools allow you to receive back communications from your employees. You can also see that if you have several concerns expressed it could alert you earlier to begin some detection and move towards prevention in your compliance program.
Three key takeaways:
Jay and I take things in a different direction this week. We consider some of the year end wrap ups and pontifications of the future that recently caught our collective eyes. Jay reflects on the greatest pro football dynasty of alltime, how it got there and where it may be going.
Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.
In today’s edition of Daily Compliance News:
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 which is centered on your consumers. In other words, it helps a compliance practitioner to anticipate all the aspects of your employees needs around compliance. This is especially true when compliance is either perceived as something that comes out of the home office or is perceived as the “Land of No.” A 360-degree view of compliance gives you the opportunity to build a new brand image for your compliance program. This is important as the Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance) mandates that for a compliance program to be effective, it must be understood by a wide variety of stakeholders.
Communications 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 simply can no longer effectively communicate in just two ways. You now communicate in a more holistic manner, and in multiple ways. If you are just thinking about communications in the classic form, you are missing something that is happening around you.
360-degrees of compliance communication is not just a classic form of communication but rather it is a communication in the concept of every interaction, whether they be planned or accidental interactions. It is all a form of communication. This is particularly true if you are a compliance professional, practitioner or Chief Compliance Officer. 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.
Three key takeaways:
Would you say empowering your employees is important? I feel pretty confident your answer is “yes”. However, the leaders I know, the leaders I work with, the leaders I teach, many of them say yes, too — but they are not taking action consistently to empower their people. The result? Leaders, teams, and companies are missing out on achieving unprecedented success! Empowering employees affects both a companies culture and the bottom-line.
In today’s episode we are digging into what is holding leaders back from effectively empowering their employees. I also walk you briefly through the “Levels of Empowerment” we teach in one of the Leadership Development sessions we teach to company leadership teams. We wrap up talking about how empowerment is a win-win-win strategy.
Choose today to put your stake in the ground, make a plan, and then take action to be the leader known for empowering employees the best! It’s time to #LevelUp!
Levels of Empowerment Blog (mentioned in episode) HERE.
If you’re looking for tangible action steps and refreshing insights to help ignite the power of your own leadership journey, sign up for my weekly leadership blog HERE.
If your business would benefit from higher-performing leaders, check out more information about the comprehensive leadership development training I do HERE.
If you want to reach out to me directly, email alyson@vanhooser.com.
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Richard Lummis and I are back and today for our initial podcast of 2020 and the second decade of the 21stCentury. Today, we take a look at leadership lessons from the rise and fall of Adam Neumann, the former CEO of WeWork.
Highlights of this podcast include:
Resources
Curse of the Cult of the Founder
The Rise and Fall of Adam Neumann
Adam Neumann’s Over the Top Style
In today’s edition of Daily Compliance News:
