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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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Compliance Week Conference Podcast

Monica Lopez Reinmiller, Megan Visk and Kelli Hooke on Hiring Compliance Professionals

In this episode of the Compliance Week 2023 Speaker Preview Podcasts series, we have the full panel of Monica Lopez Reinmiller, Megan Visk, and Kelli Hooke to discuss their panel at Compliance Week 2023, “Hiring Compliance Professionals: From Interns to Senior Compliance Roles.”

Join Monica, Kelli, and Megan as they discuss evaluating program resources and headcount. They will discuss approaches to your compliance program skills assessment, role alignment, and interviewing practices, including panel interviews and managing global time zones. Given the continued and increased focus on compliance staffing over the last years, the market for compliance professionals has become even more competitive, and assessing for skill needs and the recruitment cycle can drive long timelines; all in a session you will not want to miss.

I hope you can join me at Compliance Week 2023. This year’s event will be May 15-17 at the JW Marriott in Washington, DC. The line-up of this year’s event is simply first-rate, with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 18th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. And many others to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders, and ethics and compliance visionaries.
  • Hear from 75+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from the two SEC Commissioners, gain insights into the agency’s enforcement areas, and walk away with guidance on remaining compliant within emerging areas such as ESG disclosure, third-party risk management, cybersecurity, cryptocurrency, and more.
  • Bring actionable takeaways from your program from various session types, including ESG, Human Trafficking, Board obligations, and many others, for you to listen, learn and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

For information on the event, click here. Listeners of this podcast will receive a discount of $200 by using code TF200 on the link here.

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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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Blog

Mike Shannon, Corporate Stakeholders and Compliance

As reported in the New York Times, Mike Shannon died last week. In a 65+ year career, Shannon was associate with only one team, the St. Louis Cardinals. Signed by the Cardinals in 1958 for a bonus of reportedly $100,000; he was called to the majors in 1962. Initially he played Right Field but was later moved to 3rd Base. He played in three World Series, 1964, 1967 and 1968 for the Cardinals, winning two of the three. He retired in 1970 due to an illness and then went into broadcasting for the Cardinals, sitting in the booth for another 50 years broadcasting Cardinal games. He had a career batting average of .255, with 68 home runs and 367 runs batted in, and was elected to the Cardinals’ Hall of Fame in 2014.

My connection with Mike Shannon? In 60 plus years of attending baseball games, he is the only MLB player I ever got an autograph from. Was it worth much? Not in dollars but it meant the world to me and cemented by relationship with the Cardinals, right behind the Astros and even though Albert Pujols broke my heart in 2004.

We are in the midst of a blog post series on how to implement a ‘stakeholder’ strategy for a corporation as laid out article in the Harvard Business Review article, entitled “How to Create a Stakeholder Strategy” which proposes a data-driven approach to design, measurement, and implementation by authors Darrell Rigby, Zach First, and Dunigan O’Keeffe.

In their article, the authors the interconnected relationship between all stakeholders, stating “that every stakeholder has an impact on other stakeholders—engaged employees improve customer satisfaction, which in turn spurs growth, and so on—many CEOs are pledging to generate benefits for all their constituents: customers, workers, suppliers, communities, and investors. But few leaders have explicit strategies for doing so; most seem to rely on intuitive approaches.” The authors’ approach is to use a data driven approach, noting that companies should “bolster data from such third parties with inside insights and gain an understanding of the interdependencies among their particular stakeholders.” From there move forward to developing “a clear description of their purpose, establish criteria for evaluating progress toward it, set priorities among stakeholders, and start measuring value creation for each group. The last step is sustaining the new strategy through cultural change and by developing supporting processes and organizational structures.”

The 2019 Business Roundtable Statement on the Purpose of the Corporation, business executives pledged their companies to be businesses for  the benefit of all stakeholders, specifically including customers, employees, suppliers, communities, and shareholders. What was missing from this pronouncement was  any “explicit strategies for how they will do that.” Indeed the authors intoned that “most seem to be relying on intuitive approaches, which are hard to scale up and sustain because they’re based on leaders’ gut feelings about what matters most rather than specific criteria that can be codified to make delegated decision-making consistent and aligned with leadership’s strategic intent. Worse, when leaders whose personal visions have guided their companies leave their organizations, they take their intuitive strategies and commitment with them.”

However the authors believe that businesses firms can use data, to craft and implement effective growth strategies that recognize the complex interdependencies among stakeholders, create mutual benefits for them, and increase the net value generated collectively for their constituents.”  This sounds suspiciously similar to what the Department of Justice (DOJ) has said about the Chief Compliance Officer and compliance function having access across all data siloes so that I think a natural extension of where the authors are headed can equally apply to compliance.

Rather counter-intuitively the authors noted“For a long time the argument against holistic stakeholder strategies has been that you can’t create value across all dimensions of performance without hurting shareholder value.” Fortunately, the authors have found “a decade’s worth of data shows us that this is simply not the case.” Indeed the authors stated, “All that data was clear: The companies that create the greatest total value across all dimensions of performance don’t do so at the expense of shareholder value.” Moreover, in addition to the DOJ, the Delaware Court of Chancery in the McDonald’s decision which created the duty of oversight for corporate officers similar to the Caremark Doctrine specifically said the two corporate executives you have mandated visibility across an entire corporate organization.

The reality is that the time is now to begin moving in this integrated approach. The authors point to a Fortune survey that “found that two-thirds of U.S. adults now think a company’s primary objective should be making the world a better place. According to the 2022 Edelman Trust Barometer, adults around the world believe businesses can be unifying forces in society and so should step up to shape more-balanced policies on jobs, technology, wage inequality, climate change, discrimination, immigration, education, and health care. They want businesses to grow value for all stakeholders.”

But all this is more than simply aspirational. The authors point to “companies that have adopted stakeholder strategies, such as Costco, Microsoft, and P&G, [who] can attest, a stakeholder-based approach to running a business can make leadership roles more meaningful and rewarding. Moreover, companies that create strategies to benefit all stakeholders and establish systems for implementing them create more efficient business processes that lead to greater profitability. Of course it can be more purpose can and does equate to greater profit. But such an approach can also be a part of a prevent program. Here the authors believe such an approach can “reduce the risks of customer defections, employee turnover, loss of shareholder confidence, community protests, harsh regulations, and competitive disruptions” which can cost a company off the top line and can therefore be even more damaging and longer lasting.

Join us tomorrow where we honor another recently passed luminary and explore how to create a successful stakeholder strategy.

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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

One Month to a More Effective Compliance Program in Training and Communications – Using Social Media to Innovate in Compliance

I am a huge fan of using social media in your compliance function. But how can you get your arms around how to structure such a program for your company?  After acknowledging that social media focuses on the social aspects of communication, the most important thing to remember is that communication in social media is two-way, both inbound and outbound. It helps to bring your employee base together in an efficient manner to create an environment conducive to compliance for your organization. It also has the benefit of continued engagement. It is more than putting on training or even a set of initiatives; you can continue the conversation and enthusiasm about compliance going forward throughout the year. The authors break this down further into three parts that emphasize 1) the need to listen to and learn from user-generated content, 2) the need to engage and facilitate dialogue with employee innovators, and 3) to find an audience of early adopters to create excitement and collect feedback.

If your goal in the compliance function is to create awareness and publicize your compliance program and initiatives, social media can be a powerful tool. This is so paramount that it should become a core activity of your compliance function. Using social media tools, your compliance function can tell the story of compliance, communicate expectations, and even train. Yet again, it is simply more than a one-way tool. Just as employees are more apt to tell you about a concern immediately or soon after being trained on that issue, they may well communicate directly with you after receiving social media communication on subjects such as managing third-party relationships.
CCOs and compliance practitioners must develop a dedicated compliance strategy around social media in the context of their corporate objectives. It allows you a 360-degree view of compliance, through which you can take input from your employee base and create a compliance experience that your employees will embrace.

 Three key takeaways:

  • Never forget that social media is a two-way communication.
  • Company employees are the customers of the compliance department.
  • As with all compliance issues, assess what works for your company and appropriately tailor your social media approach.

For more information, check out The Compliance Handbook, 4th edition here.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Introduction

In this month’s offering of 31 Days to a More Effective Compliance Program, you will learn about training and communication techniques that the CCO can use to provide a well-rounded role as a CCO and facilitate a much more holistic approach to compliance in your organization. Best of all, the techniques discussed are available at little to no cost. You can do things in your method of running the CCO positions and innovations that you can bring to the compliance function in your organization.

A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is always in touch with and visible to your employees. It is about creating a distinctive brand philosophy of compliance centered on the customers of your compliance program (i.e., your employees). It helps to anticipate all the aspects of your employee’s needs around compliance, especially when compliance is perceived as new, something that comes out of the home office, or as the Land of No. It allows you to build a new brand image for your compliance program.

The objective is to build trust for the 360-degree process by determining if the goal was achieved. You can utilize surveys or focus groups to assess the impact on your target audience. Focusing on your customers of compliance allows you to identify gaps and improve the communication process for your compliance program.

Three key takeaways:

  1. Remember the definition of 360 degrees of compliance communications. It is an effort that moves the compliance identity into a holistic approach so compliance is always in touch and visible to your employees.
  2. What is your objective? What are you trying to do with your 360-degree view of compliance communications, and how are you using that mechanism to deliver the objective your compliance program desires?
  3. You need to evaluate if the message has been delivered, has been heard, and is being implemented.

For more information, check The Compliance Handbook, 3rd Edition, available here.

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Creativity and Compliance

Creativity and Compliance – ‘Yes And’ In Improv and Compliance

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network.

Ronnie’s company, Learnings, and Entertainment, utilizes the entertainment devices people use to consume information in their everyday, non-work lives and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies, and resources more accessible.

In this episode, discover how the famous “yes and” rule can revolutionize collaboration and communication skills, particularly regarding ethics and compliance. The hosts share their insights on effective communication and collaboration, emphasizing the importance of focusing on listening and reframing communication as an affirmation rather than an agreement. In addition, the podcast highlights the significance of soft skills for compliance officers and the power of “yes and” as a philosophy for corporate communications. Tune in for practical tips, techniques, and exercises to develop muscle memory and easily communicate important information. Take the chance to connect with a compliance program expert and gain more insights. Check out learningsentertainment.com or follow Ronnie Feldman on social media for more information. Subscribe to Creativity and Compliance now to enhance your communication skills and take your compliance program to the next level!

Key Highlights:

·      Applying Improv Rules to Compliance

·      The Power of ‘Yes And’ in Ethics Compliance

·      Soft Skills for Compliance Officers

·      Effective communication strategies for leaders

Notable Quote:

“The philosophies behind improvisation are so wonderful. If you ever meet someone who studied as an improv, they’re the most interesting, empathetic, thoughtful, collaborative, good listeners kinds of people because the philosophies and training that improvisers do have a great application to the business world, and I think even a tighter application to ethics and compliance.”

Resources:

Ronnie

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Great Women in Compliance

Great Women in Compliance – Joe Murphy as the Great Waltzer in Compliance

Welcome to the Great Women in Compliance Podcast, hosted by Mary Shirley and Lisa Fine.

A #GWIC can be lots of things – which is one of the best parts of this community. Today’s guest is a true advocate and supporter of women while also being one of the architects of this profession and one of our best.  It’s Joe Murphy, who co-authored the first book ever written on compliance, and is currently the Editor of Compliance and Ethics: Ideas and Answers.

Getting to know Joe is an honor and a privilege, and if you do, you will immediately learn about his passion for dance. He’s a #CCO and #GWIC in his role as Chief Cha-Cha Officer at Haddonfield Dance, and a Great Waltzer in Compliance.

Lisa was lucky to speak with this about and a number of other topics, including the genesis of Compliance and Ethics: Ideas and Answers. They also speak about what Joe sees as the best design for a CECO role to set them up for success, and about the power dynamics that are inherent in roles.

Just as the waltz can be done in a circle, we end with a discussion of what Joe has enjoyed and learned from dance that can be great lessons for life and life in compliance. Lisa and Mary are so grateful that Joe has spent some time with us.

You can find the Great Women in Compliance Podcast on the Compliance Podcast Network where you can find several other resources and podcasts to keep you up to date in the Ethics and Compliance world. You can also find the GWIC podcast on Corporate Compliance Insights where you can learn more about the podcast, stream prior episodes and catch up on Mary’s monthly column “Living Your Best Compliance Life.”

Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.

Join the Great Women in Compliance community on LinkedIn here.

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Blog

Revolutionizing Compliance with RegOps

What is RegOps and how will it revolutionize compliance? I recently visited with Anil Karmel to help understand how this concept weds multiple concepts, including data analytics, Design Thinking, AI and other tools to create a powerful mechanism to drive compliance forward.

 The term Reg Ops is coined from the combination of regulation and operations, indicating its focus on streamlining the processes related to policy adoption, regulatory compliance, and risk management. Reg Ops brings a variety of software tools and practices that leverage automation to achieve compliance quickly and efficiently. This approach, with its focus on near real-time and near continuous compliance, is ideal for businesses looking to integrate compliance as part of their core operations without sacrificing productivity. RegOps specifically addresses the unscalable problem of regulatory compliance by incorporating lessons from DevOps. Karmel’s vision was to build a platform that could provide compliant software development continuously and in real-time, thereby changing the compliance landscape. As a result, RegOps introduces a holistic solution that encompasses both human and machine processes for improved efficiency in regulatory compliance.

Chief Compliance Officers (CCOs) and compliance professionals often face the daunting task of keeping up with ever-changing regulations and demonstrating compliance in an efficient and timely manner. The traditional methods for achieving compliance are manual and time-consuming, thus falling short of effectively tackling the increasing complexity of requirements. With the growing significance of compliance in ensuring organizational success, there is a pressing need for a more streamlined and automated approach that can address the compliance challenges at scale. Karmel emphasized the necessity of transforming the way businesses handle compliance. RegOps can do this, providing an evolution of compliance that shifts away from manual processes towards embracing automation and cultural transformation. By learning from the adjacent discipline of DevOps, Karmel and his co-founder Travis Howard developed an automated, real-time solution to help businesses better address compliance challenges, regardless of their size.

One key factor that determines the success of a compliance solution is user experience. It is crucial to develop a system that not only provides seamless communication between machines but also ensures a positive human interaction with the compliance artifacts. By designing the system with the users in mind, the platform becomes more effective and impactful. A RegOps platform should be built around providing a good machine experience for machines to interact and a good human experience for humans to engage with compliance artifacts. The API-centric platform integrates with an organization’s existing tools to gather evidence in near real-time and automates the creation of tickets and real-time reports for any compliance gaps. The user-friendly reporting features cater to stakeholders at various levels, enabling them to trust and rely on the insights derived from the platform.

Regulatory compliance is an ongoing endeavor, and businesses must constantly adapt to changes and improvements in their fields. Thus, adopting a continuous process that facilitates constant refinement of practices is a necessity for successful compliance operations. By liberating businesses from time-consuming manual processes, automated technological solutions enable them to focus on improving their overall compliance outcomes. Karmel’s vision for RegOps revolves around a continuous, real-time compliance journey that is constantly evolving and adapting to users’ needs. RegOps can help provide continuous, scalable solutions that conquer regulatory compliance challenges by harnessing the power of automation and cultural transformation.

As the business landscape evolves, the importance of compliance cannot be understated. Organizations need to embrace new approaches, technology, and cultural shifts in order to stay ahead of the curve when it comes to meeting regulatory requirements. This entails not only adopting automated solutions but also fostering a culture that prioritizes compliance and understands its impact on both the organization and its stakeholders. Compliance can leverage  RegOps in transforming the compliance ecosystem. Karmel highlighted the fact that without this shift in approach, businesses would find themselves lagging behind as regulations and the demonstration of compliance continue to change. By promoting near real-time and near complete compliance solutions, such as the ones offered by RegOps, businesses can triumph over the ever-evolving compliance challenges.