Tag: compliance

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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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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Using Social Media to Innovate in Compliance

I am a huge fan of using social media in your compliance function. But how can you get your arms around how to structure such a program for your company?  After acknowledging that social media focuses on the social aspects of communication, the most important thing to remember is that communication in social media is two-way, both inbound and outbound. It helps to bring your employee base together in an efficient manner to create an environment conducive to compliance for your organization. It also has the benefit of continued engagement. It is more than putting on training or even a set of initiatives; you can continue the conversation and enthusiasm about compliance going forward throughout the year. The authors break this down further into three parts that emphasize 1) the need to listen to and learn from user-generated content, 2) the need to engage and facilitate dialogue with employee innovators, and 3) to find an audience of early adopters to create excitement and collect feedback.

If your goal in the compliance function is to create awareness and publicize your compliance program and initiatives, social media can be a powerful tool. This is so paramount that it should become a core activity of your compliance function. Using social media tools, your compliance function can tell the story of compliance, communicate expectations, and even train. Yet again, it is simply more than a one-way tool. Just as employees are more apt to tell you about a concern immediately or soon after being trained on that issue, they may well communicate directly with you after receiving social media communication on subjects such as managing third-party relationships.
CCOs and compliance practitioners must develop a dedicated compliance strategy around social media in the context of their corporate objectives. It allows you a 360-degree view of compliance, through which you can take input from your employee base and create a compliance experience that your employees will embrace.

 Three key takeaways:

  • Never forget that social media is a two-way communication.
  • Company employees are the customers of the compliance department.
  • As with all compliance issues, assess what works for your company and appropriately tailor your social media approach.

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 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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31 Days to More Effective Compliance Programs

One Month to a More Effective Training and Communications – The D&B Experience in Training and Communications

How did one company and one CCO actively use social media to make the company’s compliance culture more effective? The company was Dun & Bradstreet, Inc. (D&B), and its then CCO, Louis Sapirman, discussed D&B’s integration of social media into compliance with me.
As we advance, these tools can go a long way toward enhancing your compliance program. Recall the declination to prosecute Morgan Stanley received from the DOJ when one of its managing directors had engaged in FCPA violations. One of the reasons cited by the DOJ was 35 email compliance reminders sent over seven years, bolsters the annual FCPA training the recalcitrant managing director received. You can use your archived social media communications as evidence that you have continually communicated your company’s expectations around compliance. It is equally important that these expectations are documented.

Finally, always remember the social part of social media. Social media is a two-way 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. If you have several concerns expressed, it could alert you earlier to begin some detection and move toward prevention in your compliance program.

Three key takeaways:

  1. How do 360 degrees of communication work in compliance?
  2. Focus on the ‘social’ part of social media.
  3. Use internal corporate social media to have a conversation.

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

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Compliance Week Conference Podcast

Adam Balfour and Brian McAlhaney on Raising Your Communications and Training

In this episode of the Compliance Week 2023 Speaker Preview Podcasts series, Adam Balfour and Brian McAlhaney from Bridgestone/Firestone discuss their Case Study at Compliance Week 2023,  entitled, “From Training to Learning: How We Use Lessons from Star Wars, Jurassic Park and Top Gun to Help Employees Learn About Ethics and Compliance.”

Some of the issues they will discuss in their presentation are:

  • How one company has re-framed their compliance program pillar of “Training and Communication” to “Learning and Engagement” and hear how your program can benefit from their learnings;
  • Tried and tested tips on adult learning, including using experiences, focusing on the impact on the learner, and more; and
  • How creative, effective, and engaging learning can help enhance your ethics and compliance program brand?

I hope you can join me at Compliance Week 2023. This year’s event will be May 15-17 at the JW Marriott in Washington, DC. The line-up of this year’s event is simply first-rate, with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 18th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. And many others to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders, and ethics and compliance visionaries.
  • Hear from 75+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from the two SEC Commissioners, gain insights into the agency’s enforcement areas, and walk away with guidance on remaining compliant within emerging areas such as ESG disclosure, third-party risk management, cybersecurity, cryptocurrency, and more.
  • Bring actionable takeaways from your program from various session types, including ESG, Human Trafficking, Board obligations, and many others, for you to listen, learn and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

I hope you can join me at the event. For information on the event, click here. Listeners of this podcast will receive a discount of $200 by using code TF200 on the link here.

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31 Days to More Effective Compliance Programs

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

In this month’s offering of 31 Days to a More Effective Compliance Program, you will learn about training and communication techniques that the CCO can use to provide a well-rounded role as a CCO and facilitate a much more holistic approach to compliance in your organization. Best of all, the techniques discussed are available at little to no cost. You can do things in your method of running the CCO positions and innovations that you can bring to the compliance function in your organization.

A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is always in touch with and visible to your employees. It is about creating a distinctive brand philosophy of compliance centered on the customers of your compliance program (i.e., your employees). It helps to anticipate all the aspects of your employee’s needs around compliance, especially when compliance is perceived as new, something that comes out of the home office, or as the Land of No. It allows you to build a new brand image for your compliance program.

The objective is to build trust for the 360-degree process by determining if the goal was achieved. You can utilize surveys or focus groups to assess the impact on your target audience. Focusing on your customers of compliance allows you to identify gaps and improve the communication process for your compliance program.

Three key takeaways:

  1. Remember the definition of 360 degrees of compliance communications. It is an effort that moves the compliance identity into a holistic approach so compliance is always in touch and visible to your employees.
  2. What is your objective? What are you trying to do with your 360-degree view of compliance communications, and how are you using that mechanism to deliver the objective your compliance program desires?
  3. You need to evaluate if the message has been delivered, has been heard, and is being implemented.

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

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Daily Compliance News

May 1, 2023 – The Corporate Rot Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Stories we are following in today’s edition:

  • Bringing new tech solutions to compliance. (WSJ)
  • ChatGPT is back in Italy. (WSJ)
  • US to allow auction of CITGO. (Reuters)
  • Spotting corporate rot. (FT)

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Creativity and Compliance

Creativity and Compliance – ‘Yes And’ In Improv and Compliance

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 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.

In this episode, discover how the famous “yes and” rule can revolutionize collaboration and communication skills, particularly regarding ethics and compliance. The hosts share their insights on effective communication and collaboration, emphasizing the importance of focusing on listening and reframing communication as an affirmation rather than an agreement. In addition, the podcast highlights the significance of soft skills for compliance officers and the power of “yes and” as a philosophy for corporate communications. Tune in for practical tips, techniques, and exercises to develop muscle memory and easily communicate important information. Take the chance to connect with a compliance program expert and gain more insights. Check out learningsentertainment.com or follow Ronnie Feldman on social media for more information. Subscribe to Creativity and Compliance now to enhance your communication skills and take your compliance program to the next level!

Key Highlights:

·      Applying Improv Rules to Compliance

·      The Power of ‘Yes And’ in Ethics Compliance

·      Soft Skills for Compliance Officers

·      Effective communication strategies for leaders

Notable Quote:

“The philosophies behind improvisation are so wonderful. If you ever meet someone who studied as an improv, they’re the most interesting, empathetic, thoughtful, collaborative, good listeners kinds of people because the philosophies and training that improvisers do have a great application to the business world, and I think even a tighter application to ethics and compliance.”

Resources:

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program for 3rd Parties – Risk Ranking in the Supply Chain

One of the areas many companies do not focus on enough is possible corruption in their supply chain for goods and services provided on a company’s behalf. The FCPA risks can be just as great through those entry points as they can be through the sales side of an organization. You need to know whom your company is doing business with through this channel as much as you need to know your agents seeking business opportunities on your behalf. Most companies have exponentially more vendors than sales agents, so this task may seem daunting. However, a well-thought-out plan to risk rank your company’s third parties on the supply chain side can go a long way toward ameliorating this issue. The key is setting reasonable parameters and then managing those third parties that present real corruption risk to your organization.

This determination of the level of due diligence and categorization of a supplier should depend on a variety of factors, including such factors as whether the supplier is (1) located or will operate in a high-risk country; (2) associated, or recommended, or required by, a government official; (3) currently under corruption investigation, or has been recently convicted of any form of corruption; (4) a multinational publicly traded corporation with a recognized exemplary system of compliance and internal controls; or (5) a provider of widely available services and products that are not industry specific. You should note that any supplier with foreign government touchpoints should move up to a higher level of scrutiny.

I suggest that you create a three-tiered risk matrix consisting of (1) high-risk suppliers, (2) low-risk suppliers, and (3) minimal-risk suppliers. Below this final category is another category for providers of goods that are commonly available and pose almost no corruption risk.

It would be best to risk ranking the third parties your supply chain might engage with for FCPA exposure. It should be based on your company’s experience and risk going forward. As with all third-party risk management issues, you must “Document, Document, and Document.”

Three key takeaways:

  1. Risk rank your supply chain based on well-conceived strata.
  2. Consider not only the compliance risk but also your business risk.
  3. Only manage those suppliers who present a corruption risk.
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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program for 3rd Parties- Freight Forwarders

The FCPA world is littered with cases involving freight forwarders, brokers and agents in the shipping and express delivery arena. Both the DOJ and SEC have aggressively pursued third-party business relationships where bribery and corruption have been found. This is particularly true where companies are required to deliver goods into a foreign country through the assistance of a freight forwarder or express delivery service.
If you utilize the services of a third-party for as a freight forwarders, brokers and agents in the shipping and express delivery arena, that company’s actions will go a long way in determining your company’s FCPA liability. You must have a thoughtful process and document that process.

Three key takeaways:

  1. Express delivery services and freight forwarders present unique compliance risks.
  2. There must be a business justification to bring on new express delivery services or freight forwarders in high risk jurisdictions.
  3. Consider constructing a risk matrix in this area.