Adam Frey, Managing Director at K2 Integrity, returns to the Innovation In Compliance podcast this week. He and Tom Fox have an interesting conversation about the important role of compliance in the organization, as well as how to create a culture of compliance from the front lines.
Owning the Risk
Tom comments on one of Adam’s catchphrases, “own the risk”. Adam explains that the front line must internalize the compliance risk of their day-to-day activities, as well as the business and personal impact of noncompliance. The back office as well as the front line must work together to have a seamless compliance solution. Adam says that this involves taking a holistic view of every transaction and the risks it presents. “I think it’s important for them to understand how [compliance risks] can impact at an operational level… and that they’re an integral component of preventing the company from potentially being in noncompliance… I think it’s important not to see it as just something that is somebody else’s job.” He shares that leaders should explain the ‘why’ of compliance. “One of the things that I find is that it’s really important to demonstrate to everybody involved why something is important, not just tell them that it’s important. I think they really appreciate when they can understand it, that they have a more of a stake in the outcome.”
Compliance as a Key Function
Tom and Adam discuss why compliance should have a seat at the table. Compliance is a key business function, they both agree. When management sees compliance as a collaborative partner instead of an obstacle, the front line will more likely come to compliance professionals with potential issues. “You get better buy-in when people understand that everybody is hopefully working towards the same goal and objective,” Adam says. Every employee should also internalize compliance as an individual function. This message and attitude should come from the top, as well as the middle and bottom, Adam argues. Compliance “has to be emphasized from the top until it gets internalized to the point where it becomes bottom-up, as well,” he says.
Training & Communication
“Where do you see training as a tactic that could be utilized here?” Tom asks Adam. “Training is absolutely one of the critical components of leveraging the tone from the top but also throughout the whole organization,” Adam responds. Training should be targeted and segmented according to the exposure and risk level of trainees. “It’s important to have training not just on compliance, but you can integrate training on the actual tone from the top, on code of conduct, on compliance culture, where those issues are integrated into your training, so you’re constantly re-emphasizing and reiterating those points as part of that process,” Adam continues.
Ongoing communication about the importance of compliance is also critical. Adam shares practical tips leaders and compliance professionals can use to spread the message of compliance both in word and actions.
Adam Frey on LinkedIn