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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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From the Editor's Desk

From the Editor’s Desk – September and October, 2023 in Compliance Week

Welcome to From the Editor’s Desk, a podcast where co-hosts Tom Fox and Kyle Brasseur, EIC at Compliance Week, unpack some of the top stories that have appeared in Compliance Week over the past month, look at top compliance stories upcoming for the next month, talk some sports and generally try to solve the world’s problems.

Tom Fox and Kyle Brasseur are back. In this edition, they discuss the importance of robust compliance programs and proactive disclosures that must be balanced in today’s complex regulatory landscape. Tom underscores the significance of effective compliance measures and the innovative use of data analytics in enhancing compliance programs. He advocates for companies to prioritize these aspects to mitigate risks and improve their overall compliance posture. On the other hand, Brasseur emphasizes the need for companies to take proactive measures and implement effective compliance programs, citing a case where a bank’s failure to heed warnings resulted in a hefty financial penalty. He stresses that companies cannot afford to wait for regulatory action or assume that things will change in their favor. Join Tom Fox and Kyle Brasseur on this episode of the From the Editor’s Desk podcast as they delve deeper into this critical topic.

Highlights Include:

  • FCPA Settlement: Innovative Data Analytics Compliance
  • Deutsche Bank Affiliate’s Climate Disclosure Settlement
  • Shinhan Bank’s Lack of Compliance Program
  • Anti-Money Laundering Landscape in Europe
  • AI’s Impact on Compliance Landscape
  • Compliance Insights: Unveiling the CCO’s Perspective
  • NFL season to date
  • MLB playoffs are here
  • Dame Lillard trade and it’s fallout

 Resources:

Kyle Brasseur on LinkedIn

Compliance Week

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Blog

Pat Harned on Consumer Behavior, Corporate Ethics, and Compliance Evolution

I recently had the opportunity to visit with ECI President Pat Harned. We discussed consumer behavior, corporate ethics, and compliance evolution, which are three interconnected factors that play a crucial role in shaping the business landscape of today. We considered some of the key factors that impact them and the challenges associated with different approaches.

One of the major trends discussed in the episode is the growing importance of consumer behavior and responsibility. Consumers are increasingly willing to pay more for products from companies that are conscious of their global impact. This shift in consumer preferences has led to a rise in purpose-driven companies that prioritize ethical practices and sustainability. Employees, too, now prefer to associate themselves with organizations that have a positive impact on the world. As Tom Fox aptly puts it, “Employees are increasingly at the future workforces coming into workplaces with an expectation that they’re going to work for purpose-driven companies.”

This changing landscape has significant implications for corporate ethics and compliance. The ethics and compliance profession is evolving to emphasize corporate values and purpose. The Ethics & Compliance Initiative (ECI) aims to lead in this area by equipping professionals with the tools they need to navigate the complex regulatory environment. Experienced professionals in the ethics and compliance field are crucial for organizational success, and ECI engages senior advisors to mentor leaders and provide guidance.

However, this evolution also brings forth challenges. The role of the compliance officer is becoming more tied to senior levels of the organization, with liability attached to it. Compliance officers now have a seat at the table, but with that comes the responsibility to take action on the big problems that society is increasingly facing. As Tom Fox points out, “The next generation of employees is looking at companies and saying when are they going actually to be taking action on some of these big problems?”

To address these challenges, collaboration with regulatory bodies such as the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) is vital. The DOJ and SEC will often seek input from ethics and compliance practitioners on essential topics that impact compliance officers and businesses. This is a key role for ECI to help play with the compliance community to facilitate this public/private partnership. This partnership ensures that the compliance profession plays a leadership role in ethics, sustainability, and governance. As Tom Fox mentions, “It has been a very nice development to see that they’re interested in the input from our profession.”

The episode also highlights the importance of ECI’s role as a thought leader in the ethics and compliance space. With the convergence of various fields, such as ESG (Environmental, Social, and Governance), ethics and compliance professionals need to stay ahead of the curve. ECI is putting together a blue-ribbon commission to examine what an effective ESG effort looks like and how it ties to corporate purpose and values. This initiative aims to help companies meet the growing expectations of employees and consumers.

In conclusion, consumer behavior, corporate ethics, and compliance evolution are intertwined factors that shape the business landscape. The preferences of consumers and employees are driving the rise of purpose-driven companies, emphasizing the need for ethical practices and sustainability. The ethics and compliance profession is evolving to meet these demands, with ECI leading the way. Collaboration with regulatory bodies and thought leadership initiatives are crucial for navigating complex challenges and ensuring a positive impact on society. As we move forward, organizations need to consider the effect on consumer behavior, corporate ethics, and compliance evolution when making decisions.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Innovation: Day 4 – The ROI of Effective Compliance

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.

The data and information you collect, which might initially begin as a compliance solution or project, can be used to improve business process efficiency. The delivery of a compliance solution can enhance an overall business process. When you start to consider the compliance data points in every organization, from the Quote To Cash (QTC) sales cycle to the procure-to-pay (P2P) procurement cycle, you begin to see how compliance can be used to improve business efficiency and lead to greater profitability.

Three key takeaways:

  1. The World’s Most Ethical companies had 13.5% delta about the S&P 500 average in 2020.
  2. Companies with robust compliance programs do better financially in countries prone to corruption than companies with less effective compliance programs.
  3. What does the data tell you?

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 Through Innovation: Day 3 – The Digital Transformation of Compliance

Through restructuring, senior leadership can signal that digital transformation in compliance is critical for the future of the organization. From this point, the compliance function can work with an internal digital product design group. By doing so, the corporate compliance function can work with a team dedicated to supervising the development of the new compliance solution through product design, testing, and analysis, which will include customized generative design and analysis tools. Top management can signal the importance of the compliance digital transformation by using this dedicated team to spearhead the compliance function’s digital transformation development process.

One of the great things about the compliance world is that we are only limited by our own imaginations. If you can imagine a better way for your company to comply fully, it is at your disposal to do so. Yet, rarely do we think about the structure of how compliance activates as a way to operationalize compliance more fully. By identifying and bringing in the skills needed to move forward with compliance innovation, you can help kick-start the compliance operationalize process through a digital transformation of your compliance regime. By doing so, you may make all the difference between success and failure coming out of the Coronavirus health crisis as the world reopens for business.

Three key takeaways:

  1. Have you considered a generational team approach to a digital transformation in compliance?
  2. Have non-compliance professionals aid in compliance program development.
  3. In compliance, you are only limited by your imagination.

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

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Blog

Albemarle FCPA Enforcement Action: Part 2 – How to Hire Corrupt Agents

Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the Foreign Corrupt Practices Act (FCPA) stemming from Albemarle’s participation in corrupt schemes to pay bribes to government officials in multiple foreign countries.

According to a Non-Prosecution Agreement (NPA) with the DOJ, between 2009 and 2017, Albemarle, through its third-party sales agents and subsidiary employees, conspired to pay bribes to government officials to obtain and retain chemical catalyst business with state-owned oil refineries in Vietnam, Indonesia, and India. According to the SEC Administrative Order (Order), the bribery schemes extended into China and the UAE.

 Vietnam-His Friends

The company sales model in Vietnam included using third-party agents. The initial commission rate for the corrupt agent in question was 4.25%. However, according to the NPA, quite quickly, the corrupt agent said he needed an increase in the commission rate from 4.25 percent to “4.25% + 4% extra,” which would be used to “settle down” PetroVietnam officials and to “contribute to his friends.” Internally, the company’s Vietnam sales team “sent this information – including Vietnam Intermediary’s warning that “if ALB could not provide such extra 4% commission,” Albemarle’s competitor that had the business before Albemarle “will be kept in BSR still” – to four Albemarle sales employees who were pursuing the Company’s first business in Vietnam.”

The corrupt sales agent kept pushing for an increase in the commission rate. He next emailed “Albemarle Vietnam Sales Representative, stating, “I have received a strong message from our friend that the total commission must be fixed [sic] at 7%” and that it did not matter how the commission was allocated; only the total amount, adding, “Please find the way to add to somewhere.” The corrupt agent then tried to move the commission rate up to 10%. Finally, the Albemarle Regional Sales Director emailed the corporate VP in Europe with the following, “it is clear that ash problem is more a way to keep great attention from Albemarle and [Albemarle’s competitor].” In his response, the Albemarle vice president wrote, “If [an Albemarle global business director] agrees to pay that amount of money (which I would never do), then I will not object,” but cautioned that “if just commission increases and job for us remains the same then you have an issue…” The NPA stated, “Albemarle ultimately agreed to increase Vietnam Intermediary Company’s commission from 4.25 percent to 6.5 percent.” 

Indonesia-The Big Boss

In Indonesia, another third-party agent was used. According to the NPA, “In or around 2012, following a change in leadership at Pertamina, Albemarle engaged Indonesia Intermediary Company to act as its local agent in return for four percent commission on sales to Pertamina. According to an Albemarle memorandum, Albemarle decided to replace its third-party agent in Indonesia at the “strong[] request[]” of Pertamina Official, the “big boss” of Pertamina, because the president of the new third-party agent was a close friend of Pertamina Official, despite the fact that the third-party agent was a small company and posed a “medium” risk.”

In or around November or December 2012, the corrupt Indonesian agent “paid bribes to Pertamina officials to obtain samples of a competitor’s product, which Albemarle used to craft its bids and improve its product.” The company’s Senior Sales Manager learned about these bribes “but did not report this to Albemarle’s compliance function and did not consider terminating Albemarle’s relationship with Indonesia Intermediary Company.”

Then, in February 2013, the corrupt agent asked Albemarle to increase its commission from 4% to 10% so the agent “could pay bribes to Pertamina officials. The request was made during a meeting at Albemarle’s Singapore office and was attended by, among others, a close relative of Pertamina Official, who purportedly was a director of Indonesia Intermediary Company.

In response to the request at the meeting, Albemarle personnel told Indonesia Intermediary Company that they refused to increase the commission and that no bribes should be paid per Albemarle policy, but maintained its relationship with Indonesia Intermediary Company and never reported the conversation to Albemarle legal, compliance, or supervisory personnel. Albemarle Senior Sales Manager was aware that Indonesia Intermediary Company paid “tips” to Pertamina officials, but directed that such category not be listed in expenses.” Most ominously, the NPA concluded, “Albemarle continued to receive inside information on the bidding process from Indonesia Intermediary Company.

India-On the Holiday List

In India, the company used another corrupt agent to illegally “retain catalyst business with India’s state-owned oil company, IOCL, by avoiding Albemarle being blacklisted. This agent “which had no prior relationship or contact with Albemarle, sent a “most urgent” email to Albemarle Regional Sales Manager stating that it was aware that Albemarle had been sent a letter from IOCL asking why Albemarle should not be “sent on Holiday list. You may be required to supply six months of catalyst-free of cost.” India Intermediary further stated in the email that “[w]e can definitely help you to come out of this situation and get the orders for you in the refineries.”

The Regional Sales Manager then sent an email to the company VP, “copying four others at Albemarle, regarding “IOCL developments” and multiple consultants who had contacted Albemarle to offer “assistance to influence and get in contact with higher level to discuss on a non-official basis.” The corrupt agent knew “much detail” and as “more aggressive” and noted that India Intermediary Company “do[es] confirm, no bribing and we can put that in the agreement.”

The Regional Sales Manager stated that the company held discussions with IOCL but at each stage was “blocked by top” and that this may have been because IOCL “want us to use [sic] consultant.” He further stated that to date, IOCL had not accepted Albemarle’s “‘reasonable’ arguments” and that “indications are mostly that they will put us on the holiday list. As I see it, the time has come to consider using a consultant seriously, and if so, it must be done very fast.”

This section of the NPA dryly concluded, “Notwithstanding multiple red flags, Albemarle entered into a consulting contract with India Intermediary Company, effective July 15, 2009, signed by Albemarle Vice President. Following the engagement of India Intermediary Company, Albemarle was not put on the “holiday list” by IOCL.”

China-a Thorny Uncle

In China, the company hired yet another corrupt agent based on the recommendation of an official from China State-Owned Customer. According to the SEC Order, “Emails among Albemarle Subsidiary personnel described a senior official at China State-Owned Customer as the “uncle” of China Agent’s principal, a situation they recognized was “thorny.” Neither China Agent nor Albemarle Subsidiary personnel identified China Agent’s Principal or reported the possible familial connection to China Official in the due diligence questionnaire or other documents submitted to Albemarle compliance personnel conducting due diligence on China Agent. However, Albemarle compliance department’s due diligence revealed that China Agent had no website and was authorized to do business only a few weeks before China Agent’s Principal first met with Albemarle personnel.”

UAE-Close Friends of the (Royal) Family

In the UAE, in violation of company policy, due diligence was conducted on UAE agents only after entering sales agency agreements with the agent, including an addendum increasing its commission. The UAE Agent had close and well-publicized ties to the UAE government and royal family, contrary to the UAE Agent’s representations in its due diligence questionnaire. Although certain company personnel in the Middle East and the Netherlands knew of the UAE Agent’s involvement, they did not inform Albemarle Legal or Compliance personnel of the relationship, and no due diligence was conducted on the UAE Agent. He provided no discernable services other than conveying confidential tender evaluations and competitors’ bids obtained from the refinery and the EPC firm.

In addition to commissions that Albemarle paid to the UAE Agent, the company paid the UAE Agent an “undefined “administrative charge” equal to ten percent of its invoices for customs clearance and other non-sales services. These undocumented charges fell outside the scope of Albemarle’s agreement with the UAE Agent. Albemarle’s system of internal accounting controls provided inadequate assurances that payments to UAE agents were used for legitimate services. Moreover, Albemarle Netherlands and Albemarle Middle East, whose books and records were consolidated into Albemarle’s financial statements, lacked support for payments to UAE Agent that were recorded as legitimate commissions and business expenses.”

I have gone through all these miss-steps, prevarications, neglected red flags, and outright leadership and compliance failures to follow the most basic internal company compliance policies to show how and why these actions occurred. They present the compliance professional with numerous data points to pressure test your compliance regime.

Join us tomorrow, where we take a deep dive into actions taken by Albemarle to remediate, cooperate, and obtain the fines and penalties.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Innovation: Day 2 – Taming Complexity in Compliance

One of the lessons we have learned from various FCPA enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. Whether a corrupt employee is working to actively hide a pot of money, which can or will be used to pay a bribe, or an improper payment slips through the cracks, complexity can work to defeat a best practices compliance program. A compliance function needs visibility into a business unit, how it does business, and where its payments are going, or else it may be due to design defects or inadvertent complexity.

Compliance is now in an era of brisk innovation and evolution. It is prone to technological change and rapid obsolescence of the lawyer-driven, spreadsheets, and word document-based compliance programs. As we advance, the compliance professional needs to understand that a “package of resilience, adaptability, coordination, and inimitability becomes more attractive than the package of efficiency, understandability, manageability, and predictability.” The key is to learn how to harness complexity on a sustainable basis.

Three key takeaways:

  1. Not all complexity is bad.
  2. If you cannot figure out how a foreigner does business, you have a problem.
  3. Compliance is now properly seen as a business process.

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

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FCPA Compliance Report

FCPA Compliance Report – Jim Walton on LRN’s 2023 Code of Conduct Report

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes Jim Walton to discuss LRN’s always great annual Code of Conduct Report.

Jim Walton is a well-known compliance professional with a background in engineering and a passion for assessing and improving corporate codes of conduct effectiveness. His perspective on this topic is shaped by his extensive experience, including his current role as a Director on LRN’s Advisory Services team, where he leads their code of conduct practice. Jim believes a company’s code of conduct should reflect its character, culture, and values, serving as a foundation for its ethical culture. He emphasizes the importance of the code being a useful resource for employees, providing guidance on ethical decision-making and access to detailed information and resources. Jim also acknowledges that there is always room for improvement in corporate codes of conduct, even among some of the largest companies in the world. Join Tom Fox and Jim Walton on this FCPA Compliance Report podcast episode to dive deeply into Codes of Conduct.

Key Highlights:

  • Evaluating the Effectiveness of Company Codes of Conduct
  • Codes of Conduct Evaluation and Best Practices
  • Comprehensive and User-Friendly Code of Conduct
  • Eight Dimensions for an Effective Code of Conduct

Resources:

Jim Walton on LinkedIn

LRN

LRN 2023 Code of Conduct Report

Tom Fox

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Blog

Employment Separation: A Compliance Centric Approach

Welcome back to our blog series on building a more effective compliance program! In today’s episode, we dive into the challenges compliance professionals face when dealing with employment separation, layoffs, and managing whistleblower allegations. We’ll explore practical advice and data-driven insights to help you navigate these complex situations. So, let’s get started! While compliance practitioners may be thinking about these issues, HR professionals may need to be fully aware of their significance. By working together, compliance and HR can ensure that exit interviews are conducted with the necessary guidance and attention to compliance-related matters.

One key aspect is the importance of collaboration between the compliance, legal, and HR departments. By working together, you can identify high-risk employees who may be subject to layoffs. This proactive approach allows you to plan and ensure that all compliance requirements are met during the separation process. To further strengthen your compliance program, consider involving a compliance professional in the exit interview process. This individual can ask detailed questions and emphasize the importance of compliance and ethical conduct. By doing so, you create an opportunity to address any potential concerns or ethical issues before they escalate.

Exit interviews serve as a goldmine of information for improving your compliance program. By asking detailed questions about what works, what doesn’t work, and what the employee would like to see, you gain valuable insights into the organization’s strengths and weaknesses. This unfiltered environment allows departing employees to freely share their thoughts, providing a unique perspective that may not have been voiced during their tenure.

During exit interviews, it is essential to ask probing and insightful questions specifically related to compliance. This helps uncover any compliance issues that may have contributed to the employee’s departure and identifies areas for improvement. By understanding the employee’s role, the structure of their business unit, and their supervisors, you can tailor questions to gather the most relevant and actionable information.

When planning layoffs, it’s crucial to consider the impact on hotlines, whistleblower reports, and retaliation claims. Data mining the hotline for employees who have reported violations and promptly investigating those allegations is essential. By demonstrating that layoffs are part of a consistent and fairly applied employee separation program, you can mitigate the risk of retaliation claims.

Treating departing employees with dignity and respect is not only the right thing to do but also essential for maintaining a positive compliance culture. Rushing employees out the door without consideration can increase the risk of retaliation claims or whistleblowing. Instead, take the time to listen to their concerns, answer their questions, and provide information on employment separation issues and state unemployment law. Offering assistance in finding future employment can also help ease the transition.

Treating departing employees with dignity can also turn them into powerful advocates for your organization. In today’s highly mobilized social media world, compliance ambassadors play a crucial role in defending your organization’s reputation and recommending it to potential employees. These ambassadors can also help communicate with stakeholders, third parties, customers, local communities, board of directors, and shareholders, reinforcing your commitment to compliance.

Compliance ambassadors can be a powerful tool when regulators come knocking. Their firsthand experiences and insights can provide additional resources and support in navigating regulatory challenges. By leveraging the knowledge gained from exit interviews, organizations can better prepare for compliance audits and demonstrate a proactive approach to regulatory compliance.

Separation documents must meet Securities and Exchange Commission (SEC) requirements regarding disclosures on whistleblowing and reporting to authorities. Failure to include language specifying that employees can go to authorities has resulted in major fines against US corporations. Ensure that your separation documents comply with these SEC requirements to protect both the company and the departing employee.

In conclusion, a comprehensive and respectful approach to employment separation and managing whistleblower allegations is crucial for maintaining an effective compliance program. By collaborating with HR, involving compliance professionals in exit interviews, addressing whistleblower reports and retaliation claims, valuing departing employees, and ensuring SEC-compliant separation documents, you can mitigate risks and foster a culture of compliance within your organization. Please plan for this eventuality to avoid the ex-employee being uncooperative with the company or government. By considering the potential value of a laid-off employee, you can better prepare for these situations.

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Blog

The ROI of a Culture of Speak Up

We are now at a place where sufficient data, academic research, and actual use cases from corporations and businesses demonstrate that 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%. 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, leading to a negative Return on Equity (ROE) of between 24% and 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.

All of this leads to the key finding of reducing material litigation costs, and remember, this is not simply civil litigation but all reportable proceedings against a company, including regulatory enforcement actions, criminal sanctions sought by the Department of Justice (DOJ), and all other court proceedings. A material proceeding would have to be 5% of a company’s gross margin so the amount would be pretty high. Companies with robust whistleblower reporting systems also had 4% fewer pending lawsuits the year after increased hotline activity, improving to 6.9% fewer material lawsuits over the next three years. Additionally, overall litigation settlements of non-material matters dropped almost 20% over three years.

But the story does not end with data, numbers, or academic research. The corporate world is full of tales where a compliance solution was delivered, which made compliance more effective and improved business process efficiency and greater profitability. Data and information collected, which initially began as a compliance solution or project, can be used to improve business process efficiency. Delivering a compliance solution can enhance an overall business process. When you consider the compliance data points in every organization, from the Quote To Cash (QTC) sales cycle to the procure-to-pay (P2P) procurement cycle, you see how compliance can improve business efficiency and lead to greater profitability.

The bottom line is that creating a culture of trust that generates loyalty and passion generates productivity. Your employees are engaged and want to give their all. This means they seek opportunities to prove themselves by doing their best. Suppose you have a robust culture of speaking up, as discussed in this blog post. In that case, you will have motivated employees who can communicate business efficiency upgrades and new ideas for greater profitability.

Trust is a vital component of creating a productive and passionate company culture. Disrespect can damage trust and lead to a breakdown in employer-employee relationships. When employees feel trusted, they are empowered and motivated to give their best. This generates loyalty, passion, and productivity, creating a company culture that thrives and excels. Trust is morally right and financially smart, as it reduces worker disengagement and turnover costs. Having a robust ethos of speaking up in your organization will only drive better overall corporate culture.