Tag: CCO

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Revolutionizing Compliance Monitoring with Generative AI and Chat GPT

I recently had the opportunity to visit with Vince Walden, founder and CEO of KonaAI, for a podcast series on the uses of data driven compliance. KonaAI is the sponsor of those podcasts. This blog post series will flesh out the podcast show notes. Over the next five blog posts, we will discuss generative AI and ChatGPT in compliance, the profiles of corrupt payments, making the business case for data-driven compliance, what to ask for and how to ask for it, and some success stories. In Part 1, we will consider using generative AI and ChatGPT for compliance.

My special guest is Vince Walden, a trailblazer spearheading transformative advancements in the compliance industry through the innovative use of data and data analytics. Vince’s grounding in generative AI and Chat GPT has enabled him to push the boundaries of traditional compliance monitoring. His knack for simplifying complex concepts has won him acclaim at numerous conferences, where he frequently shares his expertise. Vince’s novel strategies are revolutionary and rapidly becoming the new standard in the field.

Together with Walden, we will explore how compliance professionals can enhance their monitoring efficiency through generative AI and Chat GPT. Having worked extensively in the compliance and data arenas, Walden understands the challenges compliance professionals face in navigating the complex regulatory landscape. He shares his expertise and highlights practical use cases of Chat GPT in compliance monitoring, demonstrating how it can streamline the decision-making process. We will provide actionable strategies for improving compliance monitoring and addressing compliance professionals’ pain points.

You have probably heard of Generative AI. What is the hype about it? Generative AI does not just analyze data—it creates or “generates” responses or outputs based on the given data. Something like a brilliant virtual assistant! Walden discussed some of the uses. He mentioned how these AI chatbots can interact directly with a compliance dashboard. This means it is more than simply about reading data—it is about interpreting it and helping make navigating tons of data more accessible. It provides recommendations, insights, and options based on what it’s looking at. This could eliminate the need to click around on your dashboard.

AI is pretty good with data. But what about qualitative information? You might be wondering if you can leave everything entirely to AI. Walden adds a bit of a reality check here by reminding us of the importance of human intervention in checking the AI’s output. There is a downside to relying exclusively on AI’s output. A compliance professional must take results at face value. There is a need for validation and fact-checking to ensure we’re not accidentally spreading misinformation or making decisions based on false statements. It’s like that saying, “Trust but verify.”

One of the key challenges associated with generative AI and chatbots in compliance monitoring is striking the right balance between automation and human oversight. While chatbots can assist in navigating and analyzing data, human judgment and expertise are still crucial in interpreting the results and making informed decisions. Compliance professionals must ensure that the rules and algorithms used by the chatbots are accurate and aligned with regulatory requirements.

Another consideration is data privacy and security. Using generative AI and chatbots within a secure platform that protects sensitive information is essential. Compliance professionals should avoid sending data to third-party providers and ensure privacy regulations are followed.

Despite these challenges, generative AI and chatbots in compliance monitoring are promising. By leveraging these technologies, compliance teams can improve efficiency, reduce costs, and enhance the overall effectiveness of their monitoring processes. The ability to customize review strategies based on different risk thresholds and areas of concern further enhances the value of these tools.

The bottom line is that generative AI and chatbots are set to revolutionize compliance monitoring by providing professionals with more efficient and interactive ways to navigate data and identify potential compliance issues. While there are tradeoffs and challenges to consider, the benefits of these technologies in terms of efficiency and cost-effectiveness are significant. Compliance professionals must exercise caution, fact-check the output of generative AI, and maintain human oversight to ensure accuracy and compliance with regulations. As compliance monitoring continues to evolve, the integration of generative AI and chatbots will undoubtedly play a crucial role in shaping its future.

The steps outlined in the article – leveraging generative AI and Chat GPT for compliance monitoring – are pivotal in helping compliance professionals achieve improved monitoring efficiency. By using generative AI to analyze large volumes of data in real time, compliance professionals can detect anomalies and potential violations more efficiently than ever. Additionally, the automation of compliance checks through Chat GPT significantly reduces the burden of manual reviews and frees up valuable time for proactive monitoring activities. These technological advancements enhance monitoring accuracy and streamline the decision-making process, allowing compliance professionals to make informed and timely decisions. By adopting these innovative tools, compliance professionals can achieve improved compliance monitoring results and ensure organizational adherence to regulations.

 Resources:

Connect with Vince Walden on LinkedIn

Check out KonaAI

Connect with Tom Fox on LinkedIn

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Navigating Transformational Changes: The Intersection of E&C and ESG

Today I would like to explore the intersection thought of ethics and compliance (E&C) and environmental, social, and governance (ESG) efforts. In a recent podcast on Report from IMPACT 2023, we explored the crucial role of ethics in guiding organizations through transformational changes. With data-driven insights and practical advice, considered the challenges, opportunities, and strategies for success in this evolving landscape.

In the face of rapid technological advancements, the importance of ethics cannot be understated. The need to build safeguards to prevent potential crashes or negative consequences. Much akin to car racing, this world has the need to moving forward with technology in a safe and responsible manner. Further and just like a skilled racer, organizations must navigate the track of progress while ensuring the ethical implications of their actions are considered. Finally always remember that brakes are not on a car to slow it down but so that you can drive fast.

As power dynamics shift and new technologies emerge, the establishment of checks and balances in this arena becomes paramount. This means that organizations need to distribute power internally both wisely and ensure ethical decision-making processes are in place. By doing so, they can safeguard against potential abuses and ensure that transformative changes are guided by integrity. I often use the visual of the billboard announcing the Eyes of Dr. T J Eckleburg from The Great Gatsby as the best way to think about having a second set of eyes on your process for process validation.

In a world undergoing rapid transformation, continuous education and expanding horizons are crucial for organizations and individuals alike. For Chief Compliance Officers (CCOs) and other compliance professionals, the importance of being adaptable and open to learning cannot be overstated. Our profession is changing as fast as any other corporate function and it is coupled with the needs of our customers changing. Who are the customers of a corporate compliance program? You can start with the multiple stakeholders identified by the Business Roundtable in their seminal Statement on the Purpose of a Corporation. It can be employees, shareholders, third-parties, vendors and business partners and those who may live in localities where your organization does business.  By embracing new perspectives and staying informed, CCOs, compliance professionals and corporate compliance functions can effectively navigate the challenges of a changing world.

A significant development highlighted in the podcast is the convergence of ESG and E&C. This integration presents a strategic risk and opportunity standpoint for organizations. By aligning environmental, social, and governance considerations with ethical and compliance practices, companies can create a holistic approach that benefits both their bottom line and society at large. Equally importantly is the mandate that the CCO and corporate compliance function should lead this effort. There is no other corporate function which has such a wide mandate, as set out by the regulators as the corporate compliance programs. One need only consider the 2019 Evaluation of Corporate Compliance Programs which led to the 2023 Evaluation of Corporate Compliance Programs to see that a corporate compliance function (and CCO) must have visibility literally across your entire corporate organization.

The demand for businesses to take positions on social issues is growing louder, both from employees and stakeholders. It well known within the compliance community and wider corporate world of the importance of both the CCO and compliance function not remaining silent on these matters. You may call this speaking truth to power but in the wider ESG world, businesses must recognize the power they hold to effect change and leverage it responsibly. By aligning their values with those of their workforce and society, they can build purpose-filled organizations that resonate with the younger generations.

I speak with many Human Resource (HR) and talent specialists and they all say that the acquisition and retention of talent will be the key market differentiator for business by mid-century. From Baby Boomers to through GenXers to Millennials and now Genders; the values and mindset of the current and upcoming workforce differ significantly from those of previous generations. To motivate and attract these individuals, organizations must listen to their ideas and incorporate them into the company’s values and purpose. By engaging with the younger generations and understanding their perspectives, board members can foster an environment that aligns with their aspirations. Businesses which try to enforce well-known and well-debunked tropes such as there is no such thing as climate change will be consigned to the dustbin of corporate failures.

Building transformative leadership and engaging forward-thinking board members pose challenges but are necessary for success. Just as talent acquisition and retention will be one of the most critical aspects of corporate survival, the importance of recruiting board members who understand current and future challenges and the need for an integrated approach will be equally critical. Critically this also means diversity on the Board. While seasoned experience is valuable, finding individuals who can bridge the gap between traditional values and the demands of a changing world is crucial. It also means new and different subject matter expertise will be critical. The Department of Justice (DOJ) has noted that a Board needs to have a compliance resource on it. The logical step is for a Board to have a Compliance Committee, chaired by a seasoned compliance professional.

It might even lead to a broader concept of a true risk management professional on the Board. Given the paradigm shift coming out of the Pandemic from disaster recovery to business resiliency to business as usually; a Board having the ability to have that strategic discussion  and lead through oversight will be a critical element as well.

Recognizing the pivotal role that ethics and compliance play in guiding organizations through transformational changes is something that is gaining traction in the corporate world. In a world that is evolving at an unprecedented pace, it is imperative to build ethical safeguards, establish checks and balances, provide appropriate oversight and adapt to the values and mindset of the younger generations. By embracing continuous education, converging ESG and E&C efforts, and taking a stand on social issues, organizations can navigate the inflection point we find ourselves in and thrive in the future.

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Report from IMPACT 2023

Report from IMPACT 2023: Katie Smith on Unleashing the Power of Ethics and Compliance Community

ECI’s IMPACT 2023 was one of the leading compliance events in 2023. At this conference, Tom Fox, the Voice of Compliance, was able to visit with several of the speakers, exhibitors, participants and one group of ethically minded Girl Scout Troop. In this limited podcast series, Report from IMPACT 2023, Tom explores many of the most cutting-edge topics in ethics and compliance through short podcast episodes. Check out the full series of interviews. You will be enlightened, informed and come away with a fuller and more thorough understanding of the most cutting-edge topics in ethics and compliance. In this episode, Tom visits with Katie Smith is a distinguished ethics and compliance professional who has devoted her career to pioneering a new path for ESG and ethics in compliance.

As the Vice Chair on the Board of Directors of ECI, she has been instrumental in shaping the organization’s future role and mission. Katie’s unique perspective on “Charting a New Course: ESG and Ethics in Compliance” is that she views it as a chance for the ethics and compliance community to unite and make a positive impact on the world. She emphasizes that there are currently no established rules in this new societal inflection point, which presents a tremendous opportunity for the ethics and compliance community to shape the future of ESG and ethics in compliance. Her enthusiasm and optimism for the beginning of this new journey are palpable. Join Tom Fox and Katie Smith on this episode of the Report from Impact podcast as they delve deeper into this fascinating topic.

 Highlights Include 

·      Conference Themes

·      Re-invigoration by the Keynote Speakers

·      What are the rules of the road now.

 Resources 

Katie Smith on LinkedIn

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Compliance Into the Weeds

Compliance into the Weeds: 3M FCPA Enforcement Action

The award winning, 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. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent FCPA enforcement action involving the Chinese business unit of 3M.

The importance of post-event documentation and monitoring in preventing fraud and corruption cannot be overstated, as highlighted by the recent FCPA incident involving 3M China. Tom believes that while training and control environment adjustments are crucial, they may not be enough to prevent misconduct if individuals are determined to commit such acts. He emphasizes the need for hard evidence, such as post-event documentation, and recommends looking to the heavily regulated pharmaceutical sector for guidance.

Matt stresses the importance of rigorous post-event documentation to ensure the legitimacy of business activities. Both Fox and Kelly gained these insights from their extensive experience in the field of compliance and their analysis of various fraud cases. To learn more about their unique perspectives on post-event documentation and monitoring, join them on this episode of the Compliance into the Weeds podcast. 

Key Highlights

·      Background facts

·      GTE in FCPA enforcement actions

·      What happens when conduct is done secretly

·      Concerns over the use of messaging apps

·      Lessons Learned

 Resources

Matt in LinkedIn

Tom –blog post on the FCPA Compliance and Ethics Blog

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Innovation in Compliance

Innovation in Compliance – Oshri Cohen on the Role of a CTO in Compliance

The role of a Chief Technology Officer (CTO) in compliance and data governance is explored in this podcast episode between Tom Fox and Oshri Cohen. They discuss the varying responsibilities of a CTO based on company size, with larger organizations focusing on strategic planning while smaller organizations have the CTO as the head engineer. The importance of the CTO in managing risks, particularly in industries like healthcare and finance, is emphasized, along with the role of the board in providing oversight. The conversation also delves into the significance of data strategy, compliance, and data governance, emphasizing the need for collaboration between the CTO and the Chief Compliance Officer (CCO). Technical due diligence and the establishment of a data commission within organizations are suggested as strategies for effective data governance. Overall, the conversation highlights the crucial role of the CTO in ensuring compliance and protecting sensitive information.

  • The Role of a CTO in Compliance
  • Data Strategy and Compliance
  • Data Governance Challenges
  • Data Governance and Startups
  • Risks in System Audits

 Resources:

Oshri Cohen on LinkedIn

Tom Fox

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 14 – Hiring A CCO: Developing The Job Profile

What should a company do when it desires to hire a CCO? To do so, a company needs to fully understand and appreciate what it needs from such a position going forward. Unfortunately, many companies do not have this insight at the beginning of the recruitment process. The key company stakeholders need to understand the full hiring process. Obviously, this will include HR and others involved in the hiring process for a CCO for the company. It could include the CEO, COO, CFO, CISO, Head of IA and others. They may need to rethink their approach to focus on what they will ask the new hire to accomplish because typically there is a disconnect between what the company thinks it needs and what it really needs.

Tom highlights the importance of developing a comprehensive job profile. Maurice Gilbert provides insights on the topic, emphasizing the need for companies to understand their specific needs and risks when creating a job profile for the CCO position. The podcast also discusses the importance of involving key stakeholders, setting realistic expectations, and considering professional growth opportunities and an attractive package for potential candidates. By involving key stakeholders in defining the role of the CCO and seeking the assistance of a professional executive recruiter, companies can find the right fit for their compliance program’s success.

Three key takeaways:

  1. Bring in your key stakeholders to flesh out the job description.
  2. Consider the top four things you would like a new CCO to accomplish in the first year.
  3. For a new CCO to succeed, the company must have a realistic expectation developed before the process begins.

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

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Executive Compliance Comp and Compliance: From Incentives to Clawbacks

There are two problems that every company must deal with at the intersection of executive compensation and compliance. The first is the presence of perverse incentives within organizations, where executives are often encouraged to take excessive risks because they personally profit from them. This misalignment of incentives can lead to unethical behavior and non-compliance, ultimately harming the organization and its stakeholders. The second is both the Securities and Exchange Commission (SEC) and Department of Justice (DOJ) mandates for executive clawbacks.

Incentives

To address this issue, companies need to tie positive incentives directly to senior executives. By holding them accountable for compliance failures, we can align their compensation with compliance objectives. This approach ensures that executives have a personal stake in maintaining ethical practices within the organization. What makes this approach unique is that it is a business response to a legal problem, rather than a government mandate. A business response is always a better way to go, as it allows organizations to take ownership of their compliance programs and tailor them to their specific needs.

Various proposals are discussed in the podcast to ensure senior executives are held personally accountable for compliance failures. One solution, suggested by William Dudley, former president of the Federal Reserve Bank of New York, is for senior management and material risk takers to forfeit their performance bond in the case of large fines. This not only disciplines individual behavior and decision-making but also incentivizes individuals to flag issues when problems arise.

Another approach, outlined in an article titled “Ties That Bind Codes of Conduct,” recommends automatic reduction of pay for officers, directors, and advisors for failures of corporate governance. Executives would agree to pay back a portion of their gross compensation for a set period before the beginning of any improprieties, regardless of their knowledge of misdeeds within the company.

While corporate leaders may not be enthusiastic about being held accountable, these proposals offer a business solution to a legal problem. Holding senior executives responsible for the conduct of others aligns with their obligations under Sarbanes-Oxley and ensures that they are not shielded from the consequences of non-compliance. Shareholders are also becoming less accepting of the argument that leaders should not be responsible for the actions of their employees.

Data from an article by Gretchen Morgenson titled “Ways to Put Your Boss’s Skin in the Game” further supports the need for accountability in executive compensation. The article explores how to make senior executives more responsible for corporate malfeasance, with implications that apply to compliance programs and compensation tied to compliance.  Creating accountability in executive compensation is a critical step towards promoting ethical business practices and compliance within organizations. By tying positive incentives to senior executives, we can ensure that they have a personal stake in maintaining compliance objectives. The proposals discussed in the podcast, such as forfeiting performance bonds and enforcing pay reductions for failures of corporate governance, offer practical solutions to address perverse incentives and drive ethical behavior.

Clawbacks

Clawbacks, often seen as a form of guarantee for businesses, play a vital role in addressing employee misconduct. These provisions, typically included in written contracts, serve as a deterrent and allow organizations to reclaim incentive or bonus funds from employees engaged in wrongful activities. It is important to note that clawbacks apply to compensation received as incentives or bonuses, rather than salary.

The SEC has provided guidance on constructing effective clawback provisions. In their final rule titled “Listing Standards for Recovery of Erroneously Awarded Compensation,” (the Rule) the SEC directs National Securities Exchanges and Associations to establish listing standards for issuers to develop and implement policies for recovering incentive-based compensation in the event of required accounting restatements.

The DOJ has also weighed in on subject of clawbacks, most recently in the 2023 Evaluation of Corporate Compliance Programs (ECCP), it stated “Are the terms of bonus and deferred compensation subject to cancellation or recoupment, to the extent available under applicable law, in the event that non-compliant or unethical behavior is exposed before or after the award was issued? Does the company have a policy for recouping compensation that has been paid, where there has been misconduct? Have there been specific examples of actions taken (e.g., promotions or awards denied, compensation recouped or deferred compensation cancelled) as a result of compliance and ethics considerations?”

In summary, both the SEC and DOJ have now laid out the foundations for both incentives and consequence management.

SEC: The SEC Rule encompasses a wide range of scenarios. Companies are required to claw back incentive compensation erroneously received by current or former executives during the three-year period preceding the required restatement date. The definition of “received” is broad, considering incentive compensation earned even if not yet paid. The recoverable amount may differ from what executives would have received based on the required restatement. The SEC rule prohibits companies from obtaining indemnity insurance to protect executives from clawbacks. This step ensures that executives are held personally accountable for their actions and fosters a culture of compliance within organizations.

DOJ: In the ECCP has emphasized the significance of clawbacks in compliance programs. The ECCP directs companies to develop and apply compensation and clawback policies, shifting the burden of financial penalties away from innocent shareholders. The clear intent to prevent companies from shielding employees involved in illegal and unethical conduct. The DOJ will consider whether a company has incentivized compliance by designing compensation systems that defer or escrow certain compensation tied to conduct consistent with company values and policies. Enforcement of a contract provisions that permit the company to recoup previously awarded compensation if the recipient of such compensation is found to have engaged in or to be otherwise responsible for corporate wrongdoing is now a critical metric that prosecutors will consider. Finally, prosecutors may consider whether provisions for recoupment or reduction of compensation due to compliance violations or misconduct are maintained and enforced in accordance with company policy and applicable laws.

 Practical Steps

To create a robust compliance program that promotes ethical behavior and compliance, companies should consider the following practical advice:

  1. Documented Policies and Procedures: It is crucial for companies to document and reflect clawback policies and procedures in their compensation agreements. This documentation showcases a commitment to compliance and serves as a deterrent for potential misconduct.
  1. Clear Disciplinary Procedures: Companies should have appropriate and clear disciplinary procedures in place when enforcing a compliance program. Publicizing disciplinary actions internally and under local law can have a deterrent effect on employees, emphasizing the consequences of engaging in unlawful or unethical behavior.
  1. Personal Accountability: The DOJ and SEC prioritize holding individuals accountable for misconduct. Prosecutors evaluate whether a corporation’s compensation agreements incorporate clawback provisions that enable penalties to be levied against employees, executives, or directors involved in criminal conduct.

 Conclusion

Clawback provisions have become a crucial element in compliance programs, promoting ethical behavior and ensuring accountability within organizations. The SEC Rule, along with the DOJ’s emphasis on clawbacks from the Monaco Memo to the ECCP, highlights the significance of these provisions in the business world. By implementing well-documented clawback policies, companies can create a culture of compliance that rewards ethical behavior and protects innocent shareholders. Both initiatives prioritize ethical practices and compliance to build a better business environment for all stakeholders.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 11 – Institutional Justice and Institutional Fairness

Companies have finally come to realize that institutional justice and fairness are perhaps the most basic tenet of any successful workplace. If employees believe they will be treated fairly, it will engender a level of trust that can work to not simply motivate employees but lead to a more successful workplace and, at the end of the day, a more profitable company. This encompasses the entire lifecycle of the employment relationship, from hiring through separation. It works in areas as seemingly disparate as compensation and incentives, discipline, promotion, and internal reporting.

On this final point, Kyle Welch and Stephen Stubben, in their 2019 paper entitled “Evidence on the Use and Efficacy of Internal Whistleblowing Systems”, noted that a robust whistleblower reporting system speaks to a functioning and ethical corporate culture. Employees who can report issues, in a fair manner, without fear of retaliation are more empowered to make the company run more efficiently and profitably. Yet an equally interesting finding was where there was robust internal reporting, employees were more likely to speak up to improve overall business processes, thereby making the company more profitable.

An often-overlooked role of any CCO or compliance professional is to help provide employees with institutional justice. If your compliance function is seen to be fair in the way it treats employees, in areas as varied as financial incentives, to promotions, to appropriate and consistent discipline meted out across the globe; employees are more likely to inform the compliance department when something goes array. If employees believe they will be treated fairly, it will go a long way to more fully operationalizing your compliance program.
Three key takeaways:

  1. The DOJ and SEC have long called for appropriate and consistent application of both incentives and discipline.
  2. The Fair Process Doctrine will help set institutional justice as the norm in your organization.
  3. Inconsistent application of discipline will destroy your compliance program credibility.

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

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Mary Shirley’s new book “Living Your Best Compliance Life”

Today, we are diving into the world of compliance with a focus on enhancing compliance programs. We’ll be exploring the key takeaways from my recent conversation with well-known compliance maven Mary Shirley and Tom Fox, where we discuss Mary’s first solo book, “Living Your Best Compliance Life: 65 Hacks and Cheat Codes to Level Up Your Ethics and Compliance Program.” This book offers valuable insights and practical advice for compliance professionals, emphasizing authenticity, engagement, and continuous improvement. Let’s discover some innovative ways to level up your ethics and compliance program!

I asked Mary about her writing style. She began by saying that she had not been confident about her writing skills. She tended to write as she spoke, which served her well for public speaking but not so well in written works. She said she had “tried very hard to improve my writing and part of that has been challenging myself to do things like publish articles because if I didn’t work on it, then it wouldn’t get addressed. The first thing I’d say about writing style is just doing my best with what I have and knowing that it’s not a predominant strength of mine but consciously working on it, listening to feedback from others.”

She added that “as cute as it sounds really being authentic.” For me, speaking in a conversational tone rather than making things legalistic is how I’ve been able to survive as a compliance officer, and it’s how I’m able to survive when talking to other compliance officers as well. We are naturally a stuffy sort of a function, and I’m not really a stuffy person, and so why hide that?”

I asked her about how she wrote, and she said that during the pandemic, she had a bit of extra time since she worked from home and did not have to commute. “Whenever the mood took me, really, I always had in the back of my mind to be thinking about things and conversations with friends and colleagues in the space to note things down as they came to me and to remember to probe people more if they shared an idea that was interesting that I thought could be featured in the book.” She also related that she had  “no kids, no pets, no plants, which I think gives me the unique opportunity to be able to leverage some of my time in ways that I appreciate that others are not necessarily able to. So for me it was, any kind of time. My weekends, I spent a lot of time doing the drafting then.”

We then turned to the chapters of her book, beginning with the first chapter, The Foundation of a Strong Compliance Program. In it Mary highlights the significance of program assessments as the foundation of a compliance program. These assessments help direct compliance programs and provide guidance to new compliance personnel. To make the process more effective, Mary suggests utilizing the free resource guide with customizable worksheets available on Corporate Compliance Insights’ dedicated page for the book. These worksheets help structure and organize ideas, making them adaptable for different environments, organizations, and cultures.

The next chapter is Team Building: Building Stronger Connections, Especially in Remote Work Settings. In the era of remote work, team building has become even more crucial. Mary emphasizes the need for dedicated team building in compliance programs, especially for remote teams. By fostering stronger connections and collaboration, compliance professionals can enhance their program’s effectiveness. Mary’s book offers valuable insights on various team building strategies that can be implemented, even with limited resources.

We next reviewed her chapter entitled, Culture and Communications: Fostering a Culture of Integrity. Creating a culture of integrity within compliance programs is essential for success. Mary’s book delves into the chapter on culture and communications, providing practical guidance on how to foster such a culture. By challenging traditional perceptions of compliance and adopting a more authentic and human-centered approach, compliance professionals can create an environment that promotes ethical behavior and compliance.

In the burgeoning age of AI in compliance, Mary’s next chapter entitled, A Humane Compliance Function: Embracing Authenticity is all the more topical. Gone are the days of a strict and robotic approach to compliance. Mary’s book encourages compliance professionals to embrace a more authentic and humane compliance function. By prioritizing compassion and authenticity, compliance programs can foster trust, engagement, and employee satisfaction. Mary provides cost-effective solutions and practical guidance on how to implement this approach effectively.

It will not surprise compliance professionals to find the next chapter, Unlocking the Power of Compliance Week: Engagement and Feedback. In this chapter Mary focuses on the celebration of Corporate Compliance and  Ethics Week as a powerful tool that is often underutilized. We discussed how Compliance Week can be used as a two-way feedback mechanism to better serve internal clients. Mary shares her experience of using fun and unconventional methods to engage employees during Compliance Week, such as games that require answering compliance questions to earn tools or rewards. This not only tests the absorption of compliance training but also identifies gaps in knowledge.

Compliance Week can provide valuable insights into areas where more work is needed. Mary suggests using Compliance Week to test basic knowledge, such as knowing where to find compliance policies or the name of the chief compliance officer. She even shares an example from her book where people got the answer wrong about the name of the chief compliance officer. By incorporating low-tech methods like easels and whiteboards, compliance professionals can gather information effectively during Compliance Week.

In conclusion, Mary Shirley’s book, “Living Your Best Compliance Life,” offers compliance professionals valuable insights and practical advice for enhancing compliance programs. By focusing on authenticity, engagement, and continuous improvement, compliance officers can create a culture of integrity and foster stronger connections within their teams. Additionally, Compliance Week provides a powerful opportunity for engagement and feedback. By utilizing this tool effectively, compliance professionals can identify areas for improvement and continuously enhance their programs. So, let’s embrace these practical tips and data-driven insights to level up our ethics and compliance programs!

Remember, Mary’s book will be released on August 15th in both Kindle and paperback formats. You can find it on Amazon.com.

You can also reach Mary at the following:

LinkedIn

Book: 65 Hacks & Cheat Codes to Level Up Your Ethics & Compliance Program | from CCI Press | Compliance Communication Handbook (corporatecomplianceinsights.com)

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 6-Six Core Principles for Compliance Incentives

In these podcast episodes, Tom Fox discusses the importance of incorporating incentives and support systems into a company’s compliance program. He presents six core principles for effective compliance incentives, emphasizing the need for simplicity, visibility, and institutional mechanisms to ensure their longevity. Fox also highlights the role of human resources in implementing compliance programs and the positive impact it can have on organizations. By understanding and implementing these principles, companies can create a culture of compliance, reduce the risk of unethical behavior, and enhance their credibility.

I have developed six core principles for incentives, adapted from a MIT Sloan Management Review article, entitled “Combining Purpose with Profits”, and formulated them for the compliance function in an anti-corruption compliance program.

1.     Compliance incentives don’t have to be elaborate or novel.

2.     Compliance incentives need supporting systems if they are to stick.

3.     Support systems are needed to reinforce compliance incentives.

4.     Compliance incentives need a “counterweight” to endure.

5.     Compliance incentive alignment works in an oblique, not linear, way.

6.     Compliance incentive initiatives can be implemented at all levels.

Obviously, this list is not exhaustive. Yet it is now more important than ever that you demonstrate tangible incentives for your employees to gain benefits, both financial and hierarchical, through doing business ethically, in compliance with your own Code of Conduct and most certainly in compliance with relevant anti-bribery laws. It is also a requirement that such actions be documented so they can be demonstrated to the regulators, if they come knocking.

Three key takeaways:

  1. Compliance incentives do not have to be elaborate or novel.
  2. You must create support systems for your compliance incentives.
  3. Compliance incentives should be implemented at all levels.