Tag: 360 degrees of communications

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Communication Through Persuasion

Such small gestures can make a difference. I recently read a biography of Dale Carnegie by Steven Watts, entitled  “Self-Help Messiah: Dale Carnegie and Success in Modern America”, penned by Ian Frazier. Carnegie is of course well known for his seminal work “How to Win Friends and Influence People” first published in 1936. I was somewhat surprised to learn that the text was largely drawn up as transcripts to lectures Carnegie was giving in New York City in the mid-1903s. Carnegie’s main thesis was to provide concrete steps on how ordinary people could help master the art of persuasion. While it has been some time since I read this book, what I recall is that to influence people, one has to listen to them. For me, the book was about how to become a better listener.

I cannot say enough about this skill for a CCO. If you hear any long-term CCO speak about their job, they will tell you it is largely about listening to people; whether those people are employees, senior management or the Chief Executive Officer (CEO) and Board members. By listening to others you not only hear, and hopefully will come to understand their concerns, but you allow them to come to decisions themselves and you are not in the position of telling them what to do. It is a skill that has served many CCOs very well for many years.
Three key takeaways:

  1. A little can mean a lot.
  2. One of the primary keys to influencing people is to listen to them.
  3. A CCO can enhance their communications by using the six principals of persuasion.
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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Using Communications to Foster your Compliance Brand

Our next lesson on compliance communications comes from best-selling authors James Patterson and David Baldacci, and it is about your brand. I have always considered your brand the image customers have of your business. It should be strategic and intentional. For a corporate compliance function, it means doing business ethically and in compliance. It could mean creating an effective compliance program that enhances business efficiency that drives greater profitability. It could mean driving an ethical culture to the very heart of your business.

However, Patterson and Baldacci discussed brand in a manner that was very different from how I think about brand and branding. They said your brand is not an image but is about your relationship with your stakeholders. For an author, that means your readers. For these writers, it means that you deliver what your readers expect, and if you are going to go in a different direction, it is important to let your readers know that you are doing something different so that if you pick up a Baldacci or a Patterson, the book will be something other than the thriller or murder mystery you are expecting.

While there are other groups you may have a relationship with as a compliance professional, looking at this from the perspective of Baldacci and Patterson, you begin to see the corporate compliance brand and your personal brand in a very different light. It can help you be both more effective as a compliance professional and lead to more professional opportunities for you as well.

Three key takeaways:

  1. How do you define your compliance brand?
  2. What is your relationship with your stakeholders?
  3. As a CCO or compliance professional, you can draw lessons from various disciplines.
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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications- One Using Communications to Drive a Speak Up Culture

How often have you thought about the role of communications in your entire hotline reporting system? I do not mean posters giving the hotline number, promising anonymity and non-retaliation. I mean using compliance communications to create a social environment where employees feel comfortable speaking up to ask questions and report concerns and they know the options for doing that.

Why do many compliance professionals find it so difficult to use compliance communications to help move the ball forward on driving a speak up culture? It begins because many conflate such communications with training. Training tends to be viewed as something that happens once per year or on a similar cadence. Yet even the DOJ has seen through the fallacy of this argument in its 2020 Update to the Evaluation of Corporate Compliance Programs when it stated, “companies have invested in shorter, more targeted training sessions to enable employees to timely identify and raise issues to appropriate compliance, internal audit, or other risk management functions.”

The 2020 Update also leads to the following questions, what resources have been available to employees to provide guidance relating to raising an issue? And, has your company assessed whether its employees know when to seek advice and whether they would be willing to speak up? Can you answer these to satisfaction of the DOJ? If not, you may have a gap in your speak up communications program.
The bottom line to all is that in compliance, you are only limited by your imagination. When you overlay creativity on your imagination, you can create something very special. And you can use compliance communications to drive a speak up culture.
 Three key takeaways:

  1. How can communications improve a speak up culture?
  2. Use communications to foster trust.
  3. A speak up culture only works when paired with a ‘listen-up’ culture.
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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 centered on your consumers. In other words, it helps a compliance practitioner to anticipate all the aspects of your employee’s needs around compliance.

This is especially true when compliance is perceived as something that comes out of the home office or as the “Land of No.” A 360-degree view of compliance allows you 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 various stakeholders.

Communication 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 can no longer effectively communicate in just two ways. You now communicate in a more holistic manner and multiple ways. If you are thinking about communications in the classic form, you are missing something happening around you.

360 degrees of compliance communication is not just a classic form of communication but communication in every interaction, whether planned or accidental. It is all a form of communication.

This is particularly true if you are a compliance professional, practitioner, or CCO. 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. It also allows you to see and hear new ideas, concepts, or ways to create a more effective compliance regime for your front-line BD folks and your first line of defense.

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?