Amanda and Cailyn discuss how companies should act on reports of retaliation, and how *not* acting can harm a workplace culture.
Listen to the episode:
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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:
What specifically are internal controls in a compliance program? The starting point is the FCPA itself, which requires issuers to devise and maintain a system of internal controls that can reasonably assure:
The DOJ and SEC, in the 2012 FCPA Guidance, stated:
Internal controls over financial reporting are the processes used by companies to provide reasonable assurances regarding the reliability of financial reporting and the preparation of financial statements. They include various components, such as: a control environment that covers the tone set by the organization regarding integrity and ethics; risk assessments; control activities that cover policies and procedures designed to ensure that management directives are carried out (e.g., approvals, authorizations, reconciliations, and segregation of duties); information and communication; and monitoring. … The design of a company’s internal controls must take into account the operational realities and risks attendant to the company’s business, such as: the nature of its products or services; how the products or services get to market; the nature of its work force; the degree of regulation; the extent of its government interaction; and the degree to which it has operations in countries with a high risk of corruption.
Three key takeaways:
Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley. In this episode, Lisa Fine has a conversation with Olga Pontes, the Chief Compliance Officer at Odebrecht SA.
What do you do when faced with the largest foreign bribery case of all time? In Odebrecht’s case they identified a fearless leader who would face the big job ahead of being the new Chief Compliance Officer of the company with optimism and strength. Meet Olga Pontes, the executive and Great Woman in Compliance tasked with leading the Compliance function and post settlement workstreams including project managing multiple monitorships!
We speak with Olga, who started out her career as an external auditor at a big four firm, about what it was like commencing the Odebrecht role three years ago compared with how she is feeling further down the track with a lot of hard work under her the belt of her team and seek her advice for other multi-national corporations who are at the beginning of a similarly daunting situation having recently settled with regulators. Olga also shares her major goal for going into 2020 with our audience.
As we go into a new year, we take the time to plan ahead and strategically think about our professional goals. In Lisa and Mary’s case it’s a time to reflect on the previous year of podcast episodes and direct our thoughts to what we wish to achieve for the Great Women in Compliance podcast in the year ahead to best benefit our audience. As always, we welcome your thoughts to inform this process. Is there anything you want to see more of, you think we should stop doing or start doing? If so, we’re all ears. We strongly believe that when you stop accepting feedback, you stop developing so we make a conscious effort to seek feedback that not only helps give our listeners what they want, but also helps us become better at our labor of love hobby, making podcasts! Wishing all of our listeners a very happy and prosperous new year ahead.
Join the Great Women in Compliance community on LinkedIn here.
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. Welcome to the first Into the Weeds podcast of the new decade and the new year. In this Part 1 of a two-part podcast series, Matt Kelly and I take a look at ten issues that we think will be significant for the compliance professional in the upcoming year.
Some of the highlights include:
Check in next week, where Matt and Tom continue the discussion.
Resources
Matt’s blog post 7 Compliance Items to Watch in 2020 in Radical Compliance.
There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the government comes knocking. The Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance) made clear that “Any well-designed compliance program entails policies and procedures that give both content and effect to ethical norms and that address and aim to reduce risks identified by the company as part of its risk assessment process.” This statement made clear that the regulators will take a strong view against a company that does not have well thought out and articulated policies and procedures against bribery and corruption; all of which are systematically reviewed and updated. Moreover, having policies written out and signed by employees provides what some consider the most vital layer of communication and acts as an internal control. Together with a signed acknowledgement, these documents can serve as evidentiary support if a future issue arises. In other words, the “Document, Document, and Document” mantra applies just as strongly to policies and procedures in anti-corruption compliance.
The specific written policies and procedures required for a best practices compliance program are well known and long established. According to the 2012 FCPA Guidance, some of the risks companies should keep in mind include the nature and extent of transactions with foreign governments (including payments to foreign officials); use of third parties; gifts, travel, and entertainment expenses; charitable and political donations; and facilitating and expediting payments. Policies help form the basis of expectations for standards of conduct in your company. Procedures are the documents that implement these standards of conduct.
Compliance policies do not guarantee employees will always make the right decision. However, the effective implementation and enforcement of compliance policies demonstrate to the government that a company is operating professionally and ethically for the benefit of its stakeholders, its employees and the community it serves.
Three key takeaways:
