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Creativity and Compliance

Creativity and Compliance – Personalization of Compliance Communications

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 that 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. Today Ronnie and Tom visited with Krista Wolff and Shannon Jamison both from Agilent Technologies on their innovative compliance communications strategies.

Krista Wolff, a professional in corporate compliance with a background in graphic design, and Shannon Jamison, a Global Compliance Operations leader for Agilent Technologies, are known for their innovative and engaging approaches to corporate compliance. Wolff believes in the importance of risk-taking and vulnerability in creating effective compliance initiatives, emphasizing the need for action, personal outreach, and the use of creativity to make compliance initiatives approachable and enjoyable. Jamison, on the other hand, advocates for fun and authenticity in compliance programs, emphasizing the importance of being true to oneself, connecting with the target audience, and fostering team collaboration. Both Wolff and Jamison’s perspectives are shaped by their unique backgrounds and experiences in the field. Join Tom Fox and Ronnie Feldman as they delve into these perspectives with Krista Wolff and Shannon Jamison on this episode of the Creativity and Compliance podcast.

Key Highlights:

  • Making Compliance Engaging and Fun
  • The Power of Involving Others in Compliance
  • Compliance Team Trading Card Showcase
  • Compliance Trading Cards and Cocktail Pairings
  • Creating a Positive Compliance Culture through Engaging Activities
  • Appreciation for Building Business Connections

Resources:

Ronnie

Guests

Shannon Jamison on LinkedIn

Krista Wolff on LinkedIn

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Data – Driven Compliance: Day 1 – Introduction to Data – Driven Compliance

In the world of compliance, data analytics and monitoring have become increasingly important. The Department of Justice (DOJ) has emphasized the significance of effective compliance programs, highlighting the role of data analytics and technology-driven approaches. Data-driven compliance helps companies gain insights into their data for informed decisions and improved compliance culture. Data-driven compliance should be designed to identify hidden money, prevent improper payments, and improve business efficiency. A key is the ability to facilitate collaboration and data sharing without compromising privacy or security, thereby enhancing the performance of predictive models.

In the Albemarle FCPA enforcement, the DOJ said for the first time that data-driven compliance is now a part of the requirements of an effective compliance program. By leveraging data and data analytics, compliance professionals more effectively manage risks, improve compliance culture, investigate issues, and ultimately keep companies out of trouble. Additionally, a robust data analytics platform will also contribute to making the business better by identifying hidden money, stopping improper payments, and enhancing overall business efficiency.

By leveraging data analytics, companies can identify hidden money, prevent improper payments, and enhance overall business efficiency. In today’s regulatory environment, the risk of not adopting data-driven compliance approaches is high, making solutions essential for companies seeking to stay compliant and improve their business practices.

 Three key takeaways:

1. The DOJ identified data analytics as a part of a best practices compliance program in the Albemarle FCPA enforcement action.

2. Data-driven compliance allows companies to access their data, search vendors, analyze transactions, run corruption and fraud tests, and even evaluate predictive models.

3. Data-driven compliance should be designed to identify hidden money, prevent improper payments, and improve business efficiency.

For more information on KonaAi, click here.

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Blog

Compliance Lessons from The Adventure of the Crooked Man

One of the great things about having a podcast network is that I get to not only explore topics that I love but I get to tie them into compliance. Perhaps the best example is my award-winning series, Trekking Through Compliance where I review all 79 episodes of Star Trek-the Original Series (TOS) and mine each episode of compliance, ethics and leadership lessons. This past summer, I began a full exploration of the Sherlock Holmes oeuvre beginning with the first series of short stories published by A. Conan Doyle in the Strand Magazine which became the book, The Adventures of Sherlock Holmes.  I made it through the original 13 stories and am now onto the second set of stories, which became the book, The Memoirs of Sherlock Holmes.

This week, I reviewed The Adventure of the Crooked Man where the focus is on the intriguing murder mystery involving the death of Colonel James Barkley. In this story Holmes is initially presented with evidence pointing towards the guilt of the Colonel’s wife, Nancy. However, Holmes, with his keen deductive skills, uncovers the presence of a third person and an oversized weasel at the murder scene, leading to a tale of deceit and betrayal.

One of the key factors impacting Sherlock Holmes’ investigation in this case is his unwavering pursuit of truth and justice. Holmes is not easily swayed by the evidence arranged against Nancy, and he meticulously examines each piece of information to uncover the real culprit. This reflects Holmes’ high ethical standard, emphasizing the importance of truth and justice over personal gain or convenience.

Another factor that plays a significant role in Holmes’ investigation is his ability to understand and empathize with the people involved. Holmes goes beyond the analytical aspects of the case and delves into the motivations and emotions of the characters. In the case of the crooked man, Holmes empathizes with him and refrains from exposing him to the police, recognizing the heavy price the man has already paid. This highlights the importance of empathy and understanding others’ perspectives in all dealings.

The story also emphasizes the concept of retribution and consequences. Holmes believes in the principle that actions have consequences, and the main antagonist in the story faces retribution for his past actions. However, this retribution is not achieved through direct legal means but rather indirectly through the consequences of his own actions. The narrative underscores the notion of karma and the ethical lesson that wrong actions can have unexpected and harmful repercussions.

Personal responsibility is another key theme in The Adventure of the Crooked Man. Both the crooked man and Colonel Barkley demonstrate personal responsibility in different ways. The Colonel’s guilt for his past actions is evident, and he is unable to escape the consequences. On the other hand, the crooked man takes responsibility for his life and makes his own way despite his disability. This encourages readers to take personal responsibility for their own actions and circumstances.

In the resolution of the case, Holmes opts for a peaceful resolution rather than seeking punishment. He recognizes that the Colonel’s death was unintentional and a result of his own guilt and horror. This demonstrates the principle that vengeance and punishment are not always the best or most ethical solutions to conflicts.

The Adventure of the Crooked Man is a captivating Sherlock Holmes story that delves into themes of truth, justice, empathy, retribution, consequences, and personal responsibility. It encourages readers to reflect on their actions and circumstances, imparting valuable ethical lessons. Holmes’ investigation in this case showcases the tradeoffs involved in balancing different factors and the challenges associated with different approaches. By considering the impact on all parties involved, Holmes is able to uncover the truth and deliver justice in his own unique way.

I found The Adventure of the Crooked Man  to be a thought-provoking episode from The Memoirs of Sherlock Holmes. Through Holmes’ investigation, listeners are taken on a journey of unraveling deceit and betrayal, while also exploring important ethical lessons. The episode highlights the significance of truth, justice, empathy, retribution, consequences, and personal responsibility in solving mysteries and making decisions. It serves as a reminder that actions have consequences and that understanding others’ perspectives is crucial in achieving a peaceful resolution.

Check out my podcast episode of The Memoirs of Sherlock Holmes here.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 17 – Improve Corporate Culture Through an Internal Podcast

One of the biggest benefits of podcasting is that it allows businesses to connect with their audience on a more personal level. Unlike traditional forms of advertising, which often come across as impersonal and sales-driven, podcasts enable businesses to build a loyal following by offering valuable and engaging content. This can include interviews with industry experts, behind-the-scenes glimpses of the business, and informative discussions on relevant topics.

Now take these same concepts of audience engagement and apply them internally to an organization. What do you potentially have? A mechanism to engage your employees, to engender trust, and to improve your overall corporate culture. Do you think this is a crazy way to improve culture? Think again about all the advantages podcasting has in place already.

A major US consumer product company started a podcast and had corporate executives on it. Who were the biggest fans of the podcast? It turned out it was the company employees, many of whom had never met their corporate executives. This allowed the executives to be humanized in a way no number of town hall meetings or other similar corporate events could ever achieve.

Podcasting is a powerful tool that corporate compliance programs can use to connect with their audience on a more personal level. By investing in podcasting, corporations can create engaging and informative audio content that will help build their ethical brand (culture) and drive employee engagement. If you want a new and different way to talk to your employees, why not try podcasting?

Since you are only limited by your imagination in compliance, why not use some of that to be creative in your compliance training and communications? Podcasting has become an essential tool for businesses to connect with their employees, establish themselves as thought leaders, and promote their values and culture. By investing in the right podcast equipment and software, corporate compliance functions can create high-quality audio content that engages their audience helps to achieve their ethical goals, and improves the culture of any organization.

 Three key takeaways:

1. You can improve employee trust and corporate culture through employee trust.

2. Communicating through a podcast can increase your brand promise with employees and other stakeholders.

3. An internal podcast can humanize your leadership to your employees.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 16 – How a Culture of Speak Up Improves Corporate Culture

What is a speak-up culture, and how does it improve the overall corporate culture? A speak-up culture is a work environment where open communication is encouraged, fostering trust and innovation. This culture is built on leadership that values listening and employee involvement in problem-solving. One of the key factors in fostering a speaking-up culture is protecting employees from retaliation. Anti-retaliation policies and procedures, training for middle managers, and a consistent, transparent process for investigating concerns are crucial to maintaining this culture. The fair process doctrine, which emphasizes transparency, consistency, and protection from retaliation, plays a significant role in building trust, encouraging engagement, and enhancing the overall organizational culture.

Empowered Employees. When employees feel empowered to contribute their ideas, it can lead to significant positive outcomes for the organization. However, fostering a speak-up culture goes beyond just listening. Retaliation should never be tolerated, and organizations must make it clear that it will not be accepted under any circumstances.

Role of Middle Managers. Middle managers play a vital role in fostering a speak-up culture. They need to be trained to listen, accept information, and report it to the appropriate channels.

Consistency and transparency. Consistency and transparency in the investigation process are also key components of a speak-up culture. Organizations must have a clear process in place for investigating concerns, and employees should be aware of this process.

Fostering a speak-up culture in the workplace is crucial for building trust, encouraging engagement, and enhancing the overall organizational culture. It requires leadership that values listening and employee involvement, as well as policies and procedures to protect employees from retaliation. Middle managers play a vital role in supporting employees and facilitating open communication. Consistency and transparency in the investigation process are essential for building trust and ensuring that employees feel comfortable bringing forward their concerns. By fostering a speak-up culture, organizations can create a culture where employees feel empowered to contribute their ideas and make a positive impact on the workplace.

 Three key takeaways:

1. Having a reporting system is important but listening is equally critical.

2. Employees must be protected from retaliation.

3. Fostering a speak-up culture can create a culture where employees feel empowered to contribute their ideas and make a positive impact on the workplace.

Do you want to improve your culture? How can you assess your culture and develop a strategy to improve it going forward? Check out the new tool, The Culture Audit. For more registration, click here.

Categories
Blog

Improving Corporate Culture Through Podcasting

Podcasting has become increasingly popular over the past decade, providing businesses with a new and innovative way to communicate with their audience. In simple terms, podcasting is the creation and distribution of audio content that can be downloaded and listened to at a later time. Podcasts are typically distributed through various platforms, such as iTunes or Spotify, and can be downloaded and listened to via a smartphone or computer.

One of the biggest benefits of podcasting is that it allows businesses to connect with their audience on a more personal level. Unlike traditional forms of advertising, which often come across as impersonal and sales-driven, podcasts enable businesses to build a loyal following by offering valuable and engaging content. This can include interviews with industry experts, behind-the-scenes glimpses of the business, and informative discussions on relevant topics.

Now take these same concepts of audience engagement and apply them internally to an organization. What do you potentially have? A mechanism to engage your employees, to engender trust and improve your overall corporate culture. Do you think this is a crazy way to improve culture? Think again about all the advantages podcasting has in place already.

A major US consumer product company started a podcast and had corporate executives on it. Who were the biggest fans of the podcast? It turned out it was the company employees, many of whom had never met their corporate executives. This allowed the executives to be humanized in a way no number of town hall meetings or other similar corporate events could ever achieve.

One of the biggest advantages of podcasting is that it is a relatively inexpensive way to reach a large audience. Unlike traditional forms of internal advertising for a compliance function, which can be expensive and difficult to track, podcasting allows businesses to reach a global audience with minimal investment. This can be particularly beneficial for corporate compliance programs which want to engage their customer base (IE., employees) in a new way that are looking to build their brand and expand their reach.

Podcasting is a powerful tool that businesses can use to connect with their audience on a more personal level. By investing in the right equipment and software, corporations can create engaging and informative audio content that will help build their ethical brand (culture) and drive employee engagement. If you want a new and different way to talk to your employees, why not try podcasting.

In today’s world, podcasting has become an essential tool for businesses to reach out to their target audience. With the rise of social media and the internet, it is crucial for businesses to utilize all available platforms to promote their products and services. Podcasting is one such platform that has gained immense popularity in recent years.

Want some other options? How about a fully produced branded podcast series for your internal compliance function. It could be two 25–30-minute episodes per month, with the guest selected by your compliance team. This format allows your corporate compliance function to tell the story of its greatest asset, its people, through interviews. Cannot get out of the country to travel? Still working remotely? Your branded podcasts give you a way to reach your employees as we continue to struggle through the Covid-19 variants. You can use the branded podcast to tell the story of compliance successes in your organization; you can include other departments to share their successes too. As with the podcast storytelling series, it would be done in a collaborative manner working with your comms team.

Want to make some short and snappy compliance communications? How about ‘Compliance News of the Day’? Have a daily curated news show of 3-4 compliance stories with a short summary of the series and how it relates to a compliance perspective to your organization. Make it fun so your employees want to check in daily. When the DOJ comes knocking and asks how often you send out compliance communications, you can point to your Compliance News of the Day as a great starting point.

As a compliance practitioner, you should strive to bring more storytelling into your compliance messaging, training and communications. If you put the employee in the shoes of the person they’re watching, they will remember it, because they will see how it applies to their lives. Such training and communication experiences will last much longer than if you drone over a written policy or show a PowerPoint. This is “expanding your classroom.” Ronnie Feldman calls this bringing memorable storytelling to your compliance communications and training.

One of the significant benefits of podcasting for a corporate compliance function is that it helps create a personal connection with the audience. Unlike other forms of internal communications, podcasting allows businesses to speak directly to their employees in a conversational and engaging manner. This helps to build trust and credibility with the audience, which can lead to increased sales and customer loyalty.

Podcasting also provides businesses with an opportunity to showcase their expertise and knowledge. By creating valuable and informative content, corporate compliance programs can establish themselves as leaders in their company to help employees facilitate issues and not be Dr. No From the Land of No. This can help to engage employees.

Another significant advantage of podcasting is that it is a highly shareable medium. Listeners can easily share podcast episodes on social media platforms, which can help to increase the reach of any corporate compliance function. This can help to attract new listeners from your employee base, as well as increase engagement with existing ones.

Since you are only limited by your imagination in compliance, why not use some of that to be creative in your compliance  communications. Podcasting has become an essential tool for businesses to connect with their audience, establish themselves as thought leaders, and promote their products and services. By investing in podcasting, corporate compliance functions can create high-quality audio content that engages their audience and helps to achieve their ethical goals and improve the culture of any organization.

Finally, if you need any help starting a podcast, ping me and I can help you get started or provide you a turnkey podcast solution.

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SBR - Authors' Podcast

SBR Authors Podcast: Matt Silverman on The Champions Network

Welcome to the Sunday Book Review, the Authors Podcast! Don’t miss out on this episode of SBR-Author’s Podcast, where Tom sits down with Matt Silverman on his book The Champions Network.

Matt Silverman is a seasoned expert and leading authority in implementing successful champion networks for organizational compliance and ethics, with years of experience in developing and building these networks. Silverstein believes the key to a successful champions’ network lies in active engagement and input from the champions, emphasizing the importance of continuous improvement and feedback.

Matt suggests a targeted approach, focusing on specific compliance areas. He advises structuring the network by identifying risks, setting up a pilot program, obtaining leadership approval, defining the scope, and clearly outlining the responsibilities of both the champions and the network leader. His experiences in successfully implementing these networks in multiple organizations have shaped this perspective, and his passion for the champions network model is evident in his work. Join Tom Fox and Matt Silverman on this episode of the SBR-Author’s Podcast podcast to delve deeper into this topic.

Key Highlights Include:

  • Gaining Leadership Support for Champions Network
  • Building a Strong Compliance and Ethics Culture
  • Establishing a Risk-Based Champions Network
  • Selecting Enthusiastic and Motivated Champions
  • Engaging and Influential Champions Training Program
  • The Value of Champions Networks in Compliance

Resources:

Matt Silverman on Linkedin

The Champions Network

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture – Day 15 – The ROI of a Culture of Speak Up

We are now at a place where there is sufficient data, academic research, and actual use cases from corporations and businesses that demonstrate good ethics and compliance programs are not simply good for business but when properly used, they lead to greater profitability.

For 15 years, Ethisphere has been collecting data around its World’s Most Ethical Company awards. Companies that receive this designation have been found to outperform their peers on various stock indices. Ethisphere calls this the “Ethics Premium.” Ethisphere Executive Vice President (EVP) Erica Salmon Byrne has noted, “In tracking how the stock prices of publicly traded honorees compare to the U.S. Large Cap Index, we found that listed World’s Most Ethical Companies outperformed the large cap sector.” In 2010 that number was a delta of 4.5%. Yet by 2020, that number had skyrocketed to 13.5%. Clearly, Ethisphere has been on to something.

Academic research has also shown the efficacy of ethics and compliance programs. George Serafeim and Paul M. Healy demonstrated in their paper, An Analysis of Firm’s Self-Reported Anti-Corruption Efforts, that companies with robust compliance programs do better financially in countries prone to corruption than companies with less effective compliance programs. Without a robust compliance program, even with high sales in a high-risk country, the sales will drop off and lead to a negative Return on Equity (ROE) of between 24% to 30%.

Dr. Kyle Welch, Assistant Professor at George Washington University (GWU), in his paper, co-authored with Stephen Stubben, Associate Professor from The University of Utah, entitled “Evidence on the Use and Efficacy of Internal Whistleblowing Systems” (Report). In this paper, Welch and Stubben reviewed some 15 years of anonymized data from NAVEX Global, Inc. This data was from the company’s hotline reporting systems. Some of the key findings included that companies with a robust whistleblower and reporting system had greater profitability and workforce productivity as measured by Return on Assets (ROA) there were fewer material lawsuits brought against the company overall and there were lower settlement costs if a lawsuit did occur. Finally, there were fewer external whistleblower reports to regulatory agencies and other authorities.

 Three key takeaways:

1. It’s not simply speaking up, it’s a culture of speaking up.

2. Companies with speak-up culture, have a material reduction in legal fines and penalties.

3. Use Companies with a speak-up culture, to have a higher ROI.

Do you want to improve your culture? How can you assess your culture and develop a strategy to improve it going forward? In this free webinar on the new tool, The Culture Audit with Tom Fox and Sam Silverstein on Tuesday, November 28, 12 CT. For more information and registration, click here.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 14 – How Investigative Triage Can Drive Culture

One area that organizations rarely consider impacting culture is the assessment and triage process in a hotline or speak-up process. A proactive approach allows for increased response time and the ability to set realistic expectations for stakeholders, but this is a key component for improving corporate culture. One mechanism not thought of by compliance professionals is the setting of service level agreements (SLAs) to set response times based on the nature of the allegation. This concept, borrowed from customer service practices, ensures that employees who come forward with complaints or allegations are provided with a clear understanding of the expected timeline for response and communication. By setting these expectations, organizations can foster a culture of open communication and trust.

Obviously, a triage process is particularly important for multinational companies that operate across different regions. With varying compliance programs and regulations in different countries, having a well-documented process becomes essential. It allows compliance departments to navigate the complexities of compliance programs and investigations, ensuring consistency and adherence to local laws.

The triage process and technology play a vital role in promoting a corporate culture. By proactively assessing and triaging complaints and allegations, organizations can increase response time and set realistic expectations for stakeholders. It is important to consider the impact on employee rights and the need for thorough investigations when making decisions about the importance of the triage process and technology in organizational compliance.

 Three key takeaways:

1. Think about how your triage process can be used to foster culture.

2. Set Service Level Agreements, make them public, and adhere to them to engender trust in your organization.

3. However, it is important to recognize the tradeoffs involved in balancing different factors when implementing a triage process.

Do you want to improve your culture? How can you assess your culture and develop a strategy to improve it going forward? In this free webinar on the new tool, The Culture Audit with Tom Fox and Sam Silverstein on Tuesday, November 28, 12 CT. For more information and registration, click here.

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Blog

Understanding the Risk – Return Relationship in Compliance

Investing in any form involves a certain level of risk, and the potential return is directly related to the level of risk taken on. This principle holds true for both private equity and venture capital investing. Private equity investors aim for positive returns on most of their investments by acquiring established businesses, while venture capital investors accept higher risk for the potential of significant returns on early-stage companies. Understanding this risk-return relationship is crucial for making informed investment decisions.

It is incumbent for every Chief Compliance Officer (CCO) and compliance professional to understand the risk-return relationship in investment and how that relationship applies to a corporate compliance function. By developing such an understanding, CCOs and compliance professionals can not only change the dynamic between seemingly disparate corporate functions such as compliance and finance; but will also allow a broader and more fulsome discussion of corporate investment in compliance resources.

One key concept in assessing investment stability and potential rewards is beta risk. Investopedia defines it as “Beta is used in the capital asset pricing model (CAPM), which describes the relationship between systematic risk and expected return for assets (usually stocks). CAPM is widely used as a method for pricing risky securities and for generating estimates of the expected returns of assets, considering both the risk of those assets and the cost of capital.” In other words, Beta risk refers to the correlation between an investment and the broader market. Compliance officers can utilize this concept to identify low-risk investments that perform well regardless of market conditions. By considering beta risk, compliance officers can make more informed decisions about allocating resources and managing compliance programs.

This highlights the concept of compliance as risk balancing, which challenges traditional notions of avoiding surprises and instead embraces potential positive surprises and opportunities for growth. This approach recognizes that managing risk can create significant growth opportunities, demonstrating the value of compliance in supporting business growth. This also provides an opportunity for the compliance function to demonstrate its role in a business’s overall growth strategies and greater profitability.

Such an approach also emphasizes the importance of CCOs and compliance professionals speaking the language of finance when discussing risk and return. By using concepts such as beta risk and understanding the different approaches to investing, compliance professionals can have more meaningful conversations with finance departments and other stakeholders. This enables them to effectively communicate the potential risks and rewards associated with compliance investments.

Obviously there are tradeoffs involved in balancing different factors when considering risk and return. While minimizing surprises may seem like a desirable goal, CCOs and compliance professionals should also be open to positive surprises can lead to unexpected growth opportunities. By managing risk effectively and considering the potential rewards, compliance officers can make strategic decisions that align with the organization’s goals.

This also leads directly to the importance of considering the compliance impact when making decisions about risk and return. Compliance programs play a crucial role in managing risk and ensuring ethical business practices. By investing in compliance initiatives, organizations can protect their reputation, mitigate legal and regulatory risks, and create a culture of integrity. Compliance investments can yield positive returns by fostering employee trust, attracting investors, and enhancing overall business performance.

Understanding the risk-return relationship in investment and compliance roles is essential for making informed decisions. Compliance officers can leverage concepts such as beta risk to identify low-risk investments that perform well regardless of market conditions. By embracing Compliance as Risk Balancing and considering the potential rewards, compliance professionals can effectively communicate the value of compliance investments to finance departments and other stakeholders. Ultimately, investing in compliance supports business growth and helps organizations navigate the complex landscape of risk and return.