Tag: communications

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31 Days to More Effective Compliance Programs

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

How can you begin to think through a best practices compliance training program? I asked Shawn Rogers, training guru, expert, and maven. Rogers advised that you ‘envision’ what your training would like as a first step. He stated, “A common mistake is jumping right to the question is which courses you want and how to deploy them. However, you must consider several things before building the program.”

You should develop some principles on what your compliance training will look like. A key way to start is by reference to the Training and Communications section of the 2023 ECCP, which states, “Prosecutors should assess the steps taken by the company to ensure that policies and procedures have been integrated into the organization, including through periodic training and certification for all directors, officers, relevant employees, and, where appropriate, agents and business partners. Prosecutors should also assess whether the company has relayed information in a manner tailored to the audience’s size, sophistication, or subject matter expertise.

Some companies, for instance, give employees practical advice or case studies to address real-life scenarios, and/or guidance on obtaining ethics advice on a case-by-case basis as needs arise.” Some of these principles include the following, What are the Guiding Principles of your compliance training? What are you trying to communicate? Is it a broad set of values you want to speak to every employee about what your organization stands for? As noted in the 2023 ECCP, a company should “examine whether the compliance program is being disseminated to, and understood by, employees in practice to decide whether the compliance program is “truly effective.”

Three key takeaways:

  1. The 2023 ECCP has a strong emphasis on compliance training.
  2. Create a set of Principles for your compliance training programs.
  3. You should always use the Guiding Principles of your compliance training program to make decisions.
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31 Days to More Effective Compliance Programs

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

Other than the skill of listening, asking questions is about as important to the compliance practitioner as any other that can be employed. Yet, equally critical is to ask the right question, which is an issue explored by Brian Grazer and Charles Fishman in their book entitled “A Curious Mind: The Secret to a Bigger Life.”
Grazer is a well-known and successful Hollywood director who has directed such movies as Splash, A Beautiful Mind, and Cinderella Man. He believes that much of his success is because he asks many questions, and “Questions are a great management tool.” This is because “Asking questions elicits information” also “creates the space for people to raise issues they are worried about that a boss, or colleagues, may not know about.” By asking questions, you allow “people to tell a different story than the one you expect.” Finally, and perhaps most significantly, “asking questions means people have to make their case for the way they want a decision to go.”

You, too, can use this simple and straightforward technique to improve your leadership qualities in the compliance function. The reason that asking questions is so much better than simply giving orders is that you have a vast talented workforce to tap into to help you do business in compliance. But the how of doing a business process that is, or should be, burned into your company can be facilitated by possibilities that are out there in your employees’ minds.  360 degrees of communication allows you to create an atmosphere where nobody is afraid to ask questions. Perhaps equally importantly, no one is afraid to answer a question.

Three key takeaways:

  1. Asking questions is a great technique to elicit information.
  2. Asking questions creates the authority in people to come up with ideas, coupled with the responsibility for moving things forward.
  3. Create an atmosphere where employees are confident to ask or answer a question.
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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Communication Across Cultures

A 360-degree approach to communications entails looking at all interactions as a way to interconnect. This means both verbal and non-verbal clues and hints. This concept can be beneficial in relating to and with cultures outside the U.S., as one of the most critical issues to a compliance function is breaking through a company’s internal cultural boundaries. In a  Harvard Business Review article entitled “Getting to Si, Ja, Oui, Hai, and Da,” Erin Meyer explained that “managers often discover that perfectly rational deals fall apart when their [business] counterparts make what seem to be unreasonable demands or don’t respect their commitments.” She laid out a five-point solution I have adapted for the CCO or compliance practitioner in communicating a compliance program across a multi-national organization. In its 2020 Update, the DOJ specified that when it comes to compliance training, a company must offer compliance training in the form and language appropriate for the audience.

Initially, look for as many cultural bridges as you can find, as it will help you understand what your international audience is communicating to you, in both verbal and non-verbal formats, during a wide variety of activities familiar to any compliance professional such as training, investigations or simple meetings where the compliance perspective must be articulated in any business setting. If you fail to have an understanding or even a person who can navigate these signs for you, here are five steps to help you out: 1) Adapt the way you express disagreement; 2) Know when to bottle it up and let it all pour out; 3) Learn how the other culture builds trust; 4) Avoid yes or no questions; and 5) Be careful about putting it in writing.

Three key takeaways:

  1. Communications in compliance must be largely drawn around trust.
  2. Look for as many cultural bridges as possible; it will help you understand what your international audience is communicating.
  3. One of the most critical issues to a compliance function is breaking through a company’s internal cultural boundaries.
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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Multiplying the Influence of Compliance

What if you could multiply the impact and effectiveness of your compliance program throughout your company? That would be a great boon to any compliance practitioner and compliance program. It is also possible by considering a 360-degree view of communications in compliance using multipliers.

Liz Wiseman is the co-author with Greg McKeown of “Multipliers: How the Best Leaders Make Everyone Smarter,” a book about the various types of leaders. They focus on two different types of leaders, Diminishers and Multipliers. Multipliers are leaders who encourage their workers’ growth and creativity, while Diminishers hinder and otherwise keep their employees’ productivity at a minimum.

Now imagine applying this leadership technique as you are trying to operationalize your compliance program fully. If you take this approach of leading by asking questions, you not only guide the functional unit but you get greater buy-in to the entire concept and process as it becomes their process. The non-compliance team may design it and have ownership over it.
Wiseman concluded by challenging each of us to multiply our influence to make those we work with work even better. You can use these skills to operationalize your compliance program more fully. If you do so, you will not only fulfill the requirements of the DOJ, as laid out in the Evaluation, but you will integrate compliance into the DNA of your company by making it a part of how you conduct your business.

Three key takeaways:

  1. Multipliers are leaders who encourage growth and creativity from their workers.
  2. Diminishers hinder and otherwise keep their employees’ productivity at a minimum.
  3. Multiply the influence of the compliance function inside and outside the company in this manner.
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31 Days to More Effective Compliance Programs

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

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

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

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

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

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

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

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

Three key takeaways:

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

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

Why do people share information? The answer to that question has important implications for every compliance practitioner and compliance program. Sharing is a primary method to communicate and connect. This is always a challenge in any far-flung international corporation, particularly for disciplines that can be viewed as home office overhead at best and the Land of No at worst. Work to hone your message through social media. Part of this is based on experimenting with what message to send and how to send it. Another aspect was based upon the Wave (of all things), its development, and coming to fruition in the early 1980s. It took some time for it to become popular, but once it was communicated to enough disparate communications, it took off. “It’s the same thing with social media. On social media, we think something will go viral because the art is beautiful or the science is full of deep analytics, but it takes time to build the community.”

This means that you will need to work to hone your message and continue to plug away to send that message out. The Morgan Stanley declination will always be instructional as one of the reasons the DOJ did not prosecute the company, as they sent out 35 compliance reminders to its workforce over seven years. Social media can be used in the same cost-effective way to get the message of compliance out and to receive information and communications back from your customer base, the company employees.

Three key takeaways:

  1. What makes your employees want to share information?
  2. Facilitate mechanisms that allow sharing with the compliance function.
  3. The Morgan Stanley declination still resonates.

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

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Creativity and Compliance

Training Jams – Using Music to Communicate E&C

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – 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 people’s entertainment devices 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, Tom and Ronnie discuss a great new series of offerings by L&E, entitled ‘E&C Training Jams.’ E&C Training Jams are an offering by L&E using music as a non-traditional way to communicate with your employees and to build an overall culture of compliance in your organization. In Training Jams, a soulful singer banters about ethics & compliance, explaining policies, sharing examples, and debunking excuses. Ronnie goes so far as to say about E&C Training Jams, “quite frankly, the coolest thing that I’ve ever made because the music gets stuck in your head, and they leave you with a smile.”

Resources:

Check out  Ronnie Feldman on LinkedIn

Check out Learnings & Entertainments on LinkedIn

Follow Ronnie Feldman on Twitter

Learnings & Entertainments 

 L&E Offerings-E&C Training Jams

E&C Jams Sizzle Reel

E&C Jams Promo Reel Landing page

E&C Jams Web Page

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Compliance Into the Weeds

Compliance Lessons from the Army

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. In this episode, we take a deep dive into the recently released GAO report on failures in the US Army SHARP program, largely around policies and procedures, with a dash of culture thrown in.  Highlights include:

·      Why has SHARP failed?

·      What is the role of policies and procedures in compliance? What about culture?

·      How can assess your own internal training and communications?

·      What are the 3 questions every compliance professional should ask?

·      What are the lessons for the civilian compliance world?

·      Where does the Army go from here?

Resources

Matt in Radical Compliance

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Creativity and Compliance

A Spoonful of Sugar

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 Compliance Podcast Network. In this episode, Tom and Ronnie begin a short series on provocative statements on compliance training and communications, followed by discussion. In this episode, why does a spoonful of sugar in the form of comedy and entertainment make compliance training and communications more engaging and effective.

Resources:

Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)

Learnings & Entertainments (Website)

60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.

Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.

Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.

Tales from the Hotline – check out some samples.