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5 Keys to Compliance Communication: Building a Culture of Trust and Engagement in Your Organization

When it comes to corporate compliance, transparent and effective communication is non-negotiable. Your employees are not only the first line of defense but are also the customers of your compliance program. A well-communicated compliance function can shift the perception of compliance from a bureaucratic formality to a valued corporate asset. To establish this, compliance professionals must adopt a 360-degree communication approach emphasizing openness, interactivity, and alignment with company values.

Here are five keys to building a robust compliance communication framework within your organization:

Start with Clear Objectives: Define the “Why”

The first step to any successful compliance communication strategy is clarity of purpose. Before launching any campaign or distributing messaging, ensure you know why you are communicating in the first place. Some key questions include: Are you aiming to educate employees about new policies?

  • Does it reinforce the importance of ethical behavior? Prompt employees to report potential issues.
  • Will each goal shape your message and each audience within your company? Tailored messaging is required to understand the importance and relevance of your compliance program from the board of directors to the newest hires (from the boardroom to the shop floor).

If you aim to increase awareness of anti-corruption policies, your communication might center around the organization’s stance on integrity and honesty. However, if you encourage a speak-up culture, the message might emphasize confidentiality, support, and the importance of reporting misconduct. Ensuring your message has a clear and measurable objective can affect how it is received and whether employees take action.

Know Your Audience: Tailor Your Message for Maximum Impact

A single compliance message may only resonate with some in your organization. In any corporation, there are multiple audiences, including employees, senior leadership, middle management, external partners, and board members, all of whom have varying levels of familiarity with compliance topics. Recognizing and addressing these differences can significantly boost your messaging’s effectiveness.

For example, your frontline employees may need a straightforward explanation of policies and accessible reporting channels. Meanwhile, senior management may focus on the high-level implications of compliance initiatives on business strategy. A one-size-fits-all approach is less effective; instead, communicate with your audience in mind, considering their needs, knowledge level, and preferred communication channels.

Embrace Two-Way Communication: Build a Culture of Trust and Feedback

One of the most crucial aspects of compliance communication is creating an open line of dialogue, both up and down the chain. Employees should feel comfortable receiving compliance information, asking questions, seeking clarification, and providing feedback. Compliance should not be a one-way street; organizations must encourage interaction and feedback to build an authentic culture of ethics and accountability.

Integrating feedback mechanisms, such as surveys, focus groups, or town hall meetings, allows you to gauge employees’ understanding of compliance topics and uncover areas for improvement. But always remember that in compliance, we are only limited by our imaginations. Dun & Bradstreet CCO Louis Sapirman implemented a “Chatter Jam” for all company employees several years ago. It was a real-time discussion on an internal platform where employees shared their views on compliance topics like the company’s Code of Conduct. This open dialogue allowed the compliance team to hear employee concerns directly and make real-time adjustments.

In addition to these formal feedback channels, informal communication should be encouraged. Ensure employees know they can speak up without fear of retaliation. In doing so, you’re promoting compliance and creating an environment where ethical concerns can be discussed openly, ultimately preventing small issues from becoming major risks. 

Consistency and Frequency: Keep Compliance Top-of-Mind

Effective compliance communication is not a one-off event but a continuous conversation. Reminders and reinforcements must be consistent and frequent for employees to internalize compliance principles. Use multiple communication channels to keep compliance messages front and center. This can include periodic emails, newsletters, short videos, or even social media-style updates on internal platforms.

Consistency doesn’t mean redundancy; it’s about finding fresh ways to reinforce fundamental compliance principles. For example, the DOJ’s 2020 FCPA Resource Guide, 2nd edition, emphasizes that regular communication about compliance expectations helps companies demonstrate their commitment to ethics and compliance. Even brief reminders can have a lasting impact. Remember Morgan Stanley’s case, where they sent 35 compliance reminders over seven years to reinforce anti-bribery policies. The company’s diligence in maintaining consistent messaging resulted in receiving a declination from the DOJ when one of its managing directors was involved in misconduct.

Regularly communicating compliance expectations also helps create a sense of normalcy around compliance issues, positioning compliance as a natural part of everyday operations rather than an occasional reminder or, worse, a reactive measure only brought up after an incident occurs.

Foster Engagement Through Storytelling and Real-World Examples

Human beings are naturally drawn to stories, so it is no surprise that storytelling is one of the most effective ways to communicate compliance issues. Sharing real-world examples of positive and negative outcomes can help employees better understand the importance of compliance and the risks associated with unethical behavior. When employees see real-life scenarios, they can more easily relate to how compliance impacts their roles and the company’s success.

Using case studies from your industry to illustrate the potential consequences of non-compliance. Highlighting scenarios where similar companies faced penalties due to lapses in compliance can make the risks feel more tangible. Conversely, sharing success stories within your organization, such as how a well-trained team prevented a potential compliance breach, can reinforce the value of compliance.

Storytelling also applies to compliance champions within the organization. Showcase individuals or teams who have exemplified ethical behavior and contributed positively to the compliance culture. Celebrate these “compliance heroes” publicly, whether in internal newsletters, company meetings, or digital screens throughout the office. Recognizing and celebrating compliance efforts in this way can have a ripple effect, inspiring others to follow suit.

Bringing it All Together: The 360-Degree Compliance Communication Model

Incorporating these five keys into your communication strategy will help establish a 360-degree approach to compliance that keeps the program visible, relevant, and actionable across the organization. It’s about more than simply sending information; it’s about creating a dynamic, two-way exchange that reinforces compliance as an integral part of your company culture. When compliance communication is objective-driven, audience-centered, interactive, consistent, and engaging, you build trust and accountability within the organization.

A robust compliance communication strategy positions your program not as a barrier to business but as an ally, helping employees navigate ethical challenges confidently. By adopting these five keys, compliance leaders can shift the perception of compliance from a mandatory obligation to a trusted, positive influence on the company’s success. It’s a win-win for employees and the organization, promoting ethical conduct while protecting its reputation and bottom line.

In the end, remember this: compliance communication is not simply about conveying rules and policies. It is also about building a culture where employees feel supported, informed, and engaged in upholding the company’s values. The real measure of success in compliance communication is when employees understand, embrace, and live out these values in their daily work.

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Principled Podcast

S11E2: Mitigating Organizational Risk Through Effective Communication

What you’ll learn on this podcast episode

As the speed of innovation and regulation continues to accelerate, learner engagement is at an all-time high, especially to help reduce organizational risk. How organizations prioritize communications is a strategy for improving learning and engagement. In this week’s episode of the Principled Podcast, host Dave Hansen, global advocacy marketing director at LRN, discusses developing effective training and communications that move the needle towards engaged learning with Stephanie Hoyt, education and communications manager for enterprise compliance at BD.

Get a copy of the global edition of LRN’s 2024 Ethics & Compliance Program Effectiveness Report. 

Guest: Stephanie Hoyt

Episode Cover - Stephanie Hoyt

Stephanie Hoyt is a seasoned ethics and compliance professional at BD, specializing in effective communication and education. With over 5.5 years of experience, she leads initiatives to enhance the company’s training curriculum, communications strategy, and Code of Conduct. Stephanie designs and implements global education curricula, tracks program metrics, and collaborates with senior management and cross-functional teams. She also serves as Communications Chair for African Americans at BD and the Women’s Initiative Network. Stephanie holds a Bachelor’s degree in International Business, Marketing, and Human Resources Management from the University of South Carolina.

Host: Dave Hansen

Episode Cover - Dave Hansen

Dave Hansen is the global advocacy marketing director at LRN, an organization focused on ethics and compliance solutions that help people worldwide do the right thing. His team drives LRN’s customer obsession by building community, deepening customer engagement, and finding meaningful opportunities for collaboration. Dave is passionate about learning, having spent most of his career in higher education or training. He loves sharing customer stories and best practices in the name of continuous improvement. Dave is a proud dad, a coffee enthusiast, a drummer, and a scuba diver. In his spare time, he enjoys cooking and reading.

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12 O’Clock High-a podcast on business leadership

12 O’Clock High, a podcast on business leadership: Dr. Karen Jacobson on A Holistic Approach to Organizational Leadership

12 O’Clock High, a podcast on business leadership, brings together stories from history, the arts, sports, movies, research, and current events to consider leadership lessons. In this episode, Get ready to hear about leadership from an expert in the field, with Tom Fox hosting the engaging episode of 12 O’Clock High, a podcast on business leadership. In this episode, Tom is joined by Dr. Karen Jacobson.

Dr. Karen Jacobson discusses the importance of understanding behavioral styles and how they impact communication in the workplace. She also shares insights from her background in chiropractic work and how it ties into her current work around behavior. The conversation explores effective leadership and communication strategies for a multigenerational workforce and the importance of adapting communication for different audiences. Dr. Jacobson also discusses the challenges and strategies for effective leadership and communication outside the United States. The conversation concludes with a discussion on understanding personal strengths and leading with them, developing communication skills for middle managers, and Dr. Jacobson’s book ‘Power Conversations’ and her upcoming book on the five generations.

Key Highlights:

  • Understanding behavioral styles is crucial for effective communication in the workplace.
  • Adapting communication for different generations and cultural differences is essential for effective workplace communication.
  • Effective leadership outside the United States requires understanding and respecting different cultures and customs.
  • Understanding personal strengths and leading with them can lead to more effective leadership.

Resources:

Karen Jacobson

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LinkedIn

Facebook

Twitter

YouTube

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Tom Fox

Instagram

Facebook

YouTube

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LinkedIn

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Innovation: Day 5 – Communication to see Around Corners

The more you can operationalize compliance, the more it works to operationalize culture in your organization. It works for all levels of a company, literally from the Boardroom to the shop floor. The DOJ and SEC recognized this when they noted in their 2020 FCPA Resource Guide, “A compliance program should apply from the board room to the supply room – no one should be beyond its reach.” Yet culture can provide more than simply an ethical foundation, and it is also a part of the business foundation of an entity.

Using such an approach to communications allows a CCO to “see around corners” and can be one of the greatest strengths of a best practices compliance program. The reason is listening. Listening is a key leadership component, and there are certainly many ways to listen. You can sit in your office and wait for a call or report on the hotline, or you can go out into the field and find out what challenges employees are facing. From this, you can work with them to craft a solution that works for the company and holds to the company’s ethical and compliance values.

Using social media tools, a CCO can move towards Thomas’ next key ingredient of a successful corporate culture, which is trust. Thomas said, “I’m obsessive about the culture that we create specifically around trust, and this is an adjustment for some people when they come here. If you join our team, there’s trust by default here. That means you trust in the competence of your teammates. You trust in their intentions and what they’re saying. At some companies, the culture is that trust is earned over time, but that means if everyone in the organization says you have to earn trust, the amount of energy that actually goes into the trust-earning process is a distraction from our mission.”

Three key takeaways:

  1. A company can fail if it does not get its culture right.
  2. Using communications to “see around corners.”
  3. Trust works as a business strategy.

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 – 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

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 360 Degrees of Compliance to Tell a Story

The 360-degree approach to compliance works with all the stakeholders in a compliance program, even the “Document, Document, and Document” stakeholders, i.e., the regulators. By using innovative techniques, one law firm came up with a mechanism to present verifiable evidence to regulators, using the basic techniques of social media in operationalizing compliance as a solution to a difficult compliance issue around, of all things, honey. This example shows how creative thinking by a lawyer in the field of import compliance led to the development of a software application using some of the concepts of social media. Once again, demonstrating the maxim that compliance practitioners (and lawyers) are only limited by their imagination, this software tool demonstrates the power of what a 360-degree view can bring to your compliance program.

Three Key Takeaways:

  1. Use the tools of social media to help tell your story of compliance.
  2. You are only limited by your imagination.
  3. Converging text, pictures, and data can be a powerful tool in compliance.
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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program for Training and Communications – Use of Social Media in Compliance

What is the compliance message inside of a corporation, and how is it distributed? In a compliance program, the largest portion of your consumers/customers are your employees. Social media presents some excellent mechanisms to communicate the message of compliance in the future. Many of the applications we use in our communications are free or available at very low cost. Why not take advantage of them and use those same communication tools in your internal compliance marketing efforts going forward?

Louis Sapirman, Vice President and Chief Ethics & Compliance Officer for Panasonic Corporation of North America – Panasonic USA, often discuss integrating social media into compliance. It would be best if you started with the tech-savvy nature of today’s workforce. It is not simply about having a younger workforce but a workforce whose primary tool for communication is social media. If your company is in the services business, it probably means your employee base is using technological tools to deliver business solutions. Finally, consider the data-driven nature of business today, so using technological tools to deliver products and solutions is something your company probably does now. Facebook, LinkedIn, Twitter, and even TikTok can all be utilized.

Finally, never forget the social part of social media. Social media is a more holistic, multiple-sided communication. Not only are you setting out expectations, but also, these tools allow you to receive back communications from your employees. The D&B experience around the name change for its Code of Conduct is but one example. You can also see that if you have several concerns expressed, it could alert you earlier to begin some detection and move toward prevention in your compliance program.

Another approach is to use audio as a part of your compliance communications. Podcasts are a great way to tell a long-form story about your compliance successes and challenges. Ronnie Feldman, the founder of L&E Entertainment, continually reminds us that the engagement of your compliance audience is through the entertainment of your compliance communications. But the key is that the audio format can be a powerful tool for you and a way to reach your employee base that you need to take advantage of. It can be as simple as interviewing employees on the importance of culture and how they use it to guide their decision-making in their daily work. Your imagination only limits you.

 Three key takeaways:

1. Incorporating social media into your compliance communications can pay big dividends.

2. Focus on the ‘social’ part of social media.

3. Consider incorporating podcasts and audio clips into your compliance communications and training.

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

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Principled Podcast

Principled Podcast – S9E10 – What You Say and How You Say It: Thoughtful Communication at AbbVie

What you’ll learn on this podcast episode

The benefits of civility in the workplace are well documented. Operating through a lens of courtesy, integrity, and respect helps align teams, lift productivity, and reduce risk. But how to create a workplace environment that prizes these things when so much of society has become so… uncivilized? How can we maintain our own composure in this trying environment, and is it important? In this episode of the Principled Podcast, host Jen Uner explores the value of thoughtful communications with Shana Fried and Marie Corchado-Stewart, two key compliance executives at the global pharmaceutical company AbbVie. Listen in as Shana and Marie share how their E&C program addresses thoughtful communications and equips employees for success in a time of considerable change both inside the organization and outside of it.  

 Guest: Shana Fried

Shana Fried – Grayscale

Shana Fried is AbbVie’s ethics and compliance officer for enterprise compliance, policies, and governance. She leads AbbVie’s compliance team supporting R&D, corporate functions and operations, EED&I, policy standards, training, governance, and communications. 

Shana joined AbbVie in 2014. A passionate advocate for patients and people, Shana has worked in both the legal and compliance teams to partner with business stakeholders on strategies to deliver products that bring value for patients. Before joining AbbVie, Shana spent nine years as an attorney in the Life Science Transactions practice group of Reed Smith LLP.   

Shana holds a Juris Doctorate from Rutgers University. She is married and has two sons, and enjoys traveling and being an advocate for social justice causes. 

Guest: Marie Corchado-Stewart

Marie Corchado-Stewart – Grayscale

Marie Corchado-Stewart is AbbVie’s director of standards, training, and equity, equality, diversity, and inclusion in the Office of Ethics and Compliance (OEC). She is responsible for AbbVie’s corporate compliance training, policies, and EED&I efforts in the OEC.   

Marie joined AbbVie in 2006 and has held various roles, all within the Office of Ethics and Compliance. This has afforded her the opportunity to work cross-functionally with various functions within the organization and gain a deep appreciation for the diversity of thought, background, and experiences needed to bring life-changing therapies to patients.   

Marie holds a master’s degree in industrial organization psychology from Chicago School of Professional Psychology. In her free time, she enjoys traveling, cooking, and spending quality time with family and friends.

Host: Jen Üner

Episode_Card_Jen_Uner_2

Jen Üner is the Strategic Communications Director for LRN, where she captains programs for both internal and external audiences. She has an insatiable curiosity and an overdeveloped sense of right and wrong, which she challenges each day through her study of ethics, compliance, and the value of values-based behavior in corporate governance. Prior to joining LRN, Jen led marketing communications for innovative technology companies operating in Europe and the US and for media and marketplaces in California. She has won recognition for her work in brand development and experiential design, earned placements in leading news publications, and hosted a closing bell ceremony of the NASDAQ in honor of the California fashion industry as founder of the LA Fashion Awards. Jen holds a B.A. degree from Claremont McKenna College.

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Innovation in Compliance

Meeting Your Clients Where They Are with Barrett Mathews

Are you still relying on outdated communication methods to reach your clients and employees? If so, you might be missing out on a huge opportunity to connect and engage with them. In this episode of Innovation in Compliance, Tom Fox speaks with Dr. Barrett Matthews, a media expert who believes in meeting clients where they are and creating authentic content to increase engagement. Barrett offers valuable insights on how businesses can leverage media to expand their reach and connect with their audience.

Dr. Barrett Matthews is a media expert with a diverse background in broadcasting, writing, and production. He has worked with industry legends like Brent Musburger and Terry Bradshaw. He eventually created a business focused on helping others embrace and leverage the power of media. Barrett now works with entrepreneurs and corporations to help them develop an authentic media presence that meets their clients where they are.

 

Barrett and Tom discuss in this episode:

  • Media has evolved and is more accessible today than ever before. Entrepreneurs and corporations need to embrace media and create content that meets their clients where they are.
  • People consume information through a variety of media forms, so businesses need to create content in multiple formats (e.g., podcasts, books, social media, etc.) to reach a wider audience.
  • Authenticity is key in creating engaging media content. Clients don’t necessarily buy the content itself, but rather the person behind it. Businesses should be open to showing their human side and not strive for perfection.
  • A documentary film can be a powerful way to showcase a business’s authenticity and human side. By delving into why a business does what it does, potential clients can connect with the business on a deeper level.
  • Deliver your content on the platforms where your target audience is present; this is essential for your business to succeed.
  • Ego-based marketing is not effective as it only promotes what makes a business owner comfortable. 
  • Build a strong brand by delivering on the promises you made to your customers, and exceeding their expectations. Your customers will refer your business to others, which can boost your brand recognition.
  • Podcasting is an excellent medium for those who are passionate about something because it’s easier to talk about a topic than to write a book on it.
  • Barrett is involved in two initiatives called iChange Nations and Media Monarch, where he aims to promote civility worldwide and teach grassroots journalism to people in different countries.
  • Barrett has a video training program available on his website about how to use media to gain more clients.

 

KEY QUOTES

“If you think that you have clients all over the place, you need to meet them where they are. Meaning that if they listen to podcasts, you better have one. If they read books, you better have one, and so forth and so on.” – Dr. Barrett Matthews

 

“People don’t necessarily buy your content as much as they buy you when it comes to the media you put out.” – Dr. Barrett Matthews

 

“Marketing is what you say about yourself to people. Your brand is what people say about you.” – Dr. Barrett Matthews

 

Resources:

Barrett Matthews on LinkedIn | Instagram | Twitter | Facebook  | Media Boss Podcast

Five Ways to Paying Clients

iChange Nations