Tag: 360 degrees of communication

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Twitter and 360-degrees of Communication

Even with the Elon Musk defenestration of Twitter, one of the ways that CCOs and compliance practitioners can better use 360 degrees of communication is through this tool. In an MIT Sloan Management Review article entitled “How Twitter Users Can Generate Better Ideas,” authors Salvatore Parise, Eoin Whelan, and Steve Todd found that “employees with a diverse Twitter network – one that exposes them to people and ideas they don’t already know – tend to generate better ideas.” Their research led them to three interesting findings: 1) Employees who used Twitter had better ideas than those who did not do so; 2) There was a link between the amount of diversity in employees’ Twitter networks and the quality of their ideas; and 3) Twitter users who combined idea scouting and idea connecting were the most innovative. Their research certainly confirms the experience of Louis Sapirman during his time as CCO at Dun & Bradstreet.

The key concept for the compliance profession is the roles of Idea Scout and Idea Connector. An “idea scout is an employee who looks outside the organization to bring in new ideas. An idea connector is someone who can assimilate external ideas and find opportunities within the organization to implement these new concepts.” It is the ability to identify, assimilate and exploit new compliance ideas, which makes this concept so powerful. However, to improve your compliance innovation, “you need to maintain a diverse network while also developing your assimilation and exploitation skills.”
Twitter can be a powerful tool for the compliance practitioner. It is one of the only tools that can work both inbounds for you to obtain information and insight and in an outbound manner, where you can communicate with your compliance customer base and your employees. It would be best if you worked to incorporate one or more of the techniques to help you burn compliance into the DNA fabric of your organization.

Three key takeaways:

  1. Twitter can be a powerful tool for the compliance practitioner.
  2. Data mine Twitter for best practices and see what the regulators may be saying.
  3. Curiosity may have killed the cat, but it makes for a far better and more effective compliance practitioner.
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31 Days to More Effective Compliance Programs

Day 9 | 360 Degrees of Compliance Communications


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:

  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?
Categories
31 Days to More Effective Compliance Programs

Day 9 | 360 degrees of compliance communications

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:

  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?