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 2020 Update 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.
The best example I can provide to you is a story told to me by Louis Sapirman, Vice President and Chief Ethics and Compliance Officer at Panasonic Corporation of North America – Panasonic USA. This story happened to him in Argentina when he was the CCO at Dun & Bradstreet (D&B). Argentina has an interesting form of illegal conduct, which is an open black market for the changing of currency. Sapirman was with a colleague who was one of the leaders from the company’s South American operations and they went into a convenience store. The person who was going to sell him the product suggested that he go just around the corner and change money on the black market where he could get a much better exchange rate, almost a 100 percent difference in the exchange rate; he declined to do so. Sapirman paid and received the established bank rate in the small transaction.
He had not considered role modeling that compliance. About six months later one of his team members was in Mexico speaking to the leader of the D&B operation there. The non-compliance function employee said that he was the person who had been with Sapirman. He recounted the story of doing the right thing, when literally no one was watching. That is the power of 360-degrees in communication.
Three key takeaways:
- 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
- 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?
- Evaluate. You need to evaluate three factors: 1) has the message been delivered; 2) has it been heard; and 3) is it being implemented?