Tag: compliance

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Great Women in Compliance

Great Women in Compliance – Nicole Di Schino – The Compliance Education Fanatic

Welcome to the Great Women in Compliance Podcast, hosted by Mary Shirley and Lisa Fine.

Most E&C professionals know that you can have the best practices and policies, but if they are not understood by your employees and teams, they cannot be effective. And some of us, like today’s guest, Nicole Di Schino, help us with that next step in our training programs. She calls herself the “Compliance Education Fanatic,” and you will understand why after hearing this episode. Nicole discusses the importance of having creative and interactive training, and also how using training with a choice of a “best” answer is better than letting people pick a clear right answer.

Nicole and Lisa also talk about how different ways to communicate with and provide training for those in different generations, particularly with Gen Z.

You can find the Great Women in Compliance Podcast on the Compliance Podcast Network where you can find several other resources and podcasts to keep you up to date in the Ethics and Compliance world. You can also find the GWIC podcast on Corporate Compliance Insights where you can learn more about the podcast, stream prior episodes, and catch up on Mary’s monthly column “Living Your Best Compliance Life.”

Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.

Join the Great Women in Compliance community on LinkedIn here.

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31 Days to More Effective Compliance Programs

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

One issue that needs to be considered by compliance professionals around compliance training is compliance training governance. Yet a multinational organization subject to the FCPA faces many legal and regulatory risks, and often many of those risks are “owned” by organizations outside the compliance function. How can your organization create a comprehensive compliance training program covering its risk profile?

Every multinational organization will have a broad risk portfolio typically owned across the organization. Consider compliance risk, fraud risk, reputational risk, financial accounting risk, and discrimination risk. These are a small sample of risks; many will not be “owned” by the corporate compliance function. This presents a real challenge when creating a comprehensive compliance training program covering a company’s legal, regulatory, compliance, and reputational risks. Well-know compliance training maven Shawn Rogers suggests “establishing a corporate Compliance Training Governance Committee that looks at the company’s overall risk profile and builds a cross-functional and comprehensive multi-year training plan that effectively addresses all of the risks in a company’s risk portfolio.”

A Compliance Training Governance Committee will allow your organization to effectively establish a multi-year training plan, help in vendor selection and engage in course creation. Rogers said, “One of the biggest benefits has been its predictability to the compliance training program. Every stakeholder from a risk-owning organization knows exactly when their function will have their course deployed over the three-year calendar. They can plan resources, they have a long lead-time to develop the courses, and during their off-years, they can do communications campaigns and events to keep their risk top-of-mind.”

Three key takeaways: 

  1. Why your organization should create a Compliance Training Governance Committee.
  2. Who should be on the Compliance Training Governance Committee?
  3. How should the Compliance Training Governance Committee work going forward?
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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – 10 Compliance Training Program Design Objectives

Well-known compliance training guru Shawn Rogers has developed ten design objectives for establishing your compliance program training design objectives. It would be best if you considered doing the same for your organization. Your organization may value other objectives. What the government has told us since the original FCPA Resource Guide back in 2012 is that it expects a well throughout the approach. If you consider your design objectives early in the planning phase, it will not only meet this requirement but also become a roadmap for your program implementation easier. Finally, you can pivot more quickly in this new era as new compliance risks emerge.

Three key takeaways:

  1. What are your design objectives?
  2. They should be dynamic, not static.
  3. You should use them as touchpoints going forward.
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Sunday Book Review

Sunday Book Review: May 21, 2023 – The Employee Engagement Edition

In the Sunday Book Review, I consider books that interest the compliance professional, the business executive, or anyone curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest me. In today’s edition of the Sunday Book Review, we look at books on employee engagement:

  • The Truth About Employee Engagement: A Fable About Addressing the Three Root Causes of Job Misery by Patrick M. Lencioni
  • The Coaching Habit: Say Less, Ask More & Change the Way You Lead Forever by Michael Bungay Stanier
  • Carrots and Sticks Don’t Work: Build a Culture of Employee Engagement with the Principles of RESPECT by Paul L. Marciano
  • The Employee Experience Advantage: How to Win the War for Talent by Giving Employees the Workspaces they Want, the Tools they Need, and a Culture They Can Celebrate by Jacob Morgan
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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 – Twitter and 360-degrees of Communication

Even with the Elon Musk defenestration of Twitter, one of the ways that CCOs and compliance practitioners can better use 360 degrees of communication is through this tool. In an MIT Sloan Management Review article entitled “How Twitter Users Can Generate Better Ideas,” authors Salvatore Parise, Eoin Whelan, and Steve Todd found that “employees with a diverse Twitter network – one that exposes them to people and ideas they don’t already know – tend to generate better ideas.” Their research led them to three interesting findings: 1) Employees who used Twitter had better ideas than those who did not do so; 2) There was a link between the amount of diversity in employees’ Twitter networks and the quality of their ideas; and 3) Twitter users who combined idea scouting and idea connecting were the most innovative. Their research certainly confirms the experience of Louis Sapirman during his time as CCO at Dun & Bradstreet.

The key concept for the compliance profession is the roles of Idea Scout and Idea Connector. An “idea scout is an employee who looks outside the organization to bring in new ideas. An idea connector is someone who can assimilate external ideas and find opportunities within the organization to implement these new concepts.” It is the ability to identify, assimilate and exploit new compliance ideas, which makes this concept so powerful. However, to improve your compliance innovation, “you need to maintain a diverse network while also developing your assimilation and exploitation skills.”
Twitter can be a powerful tool for the compliance practitioner. It is one of the only tools that can work both inbounds for you to obtain information and insight and in an outbound manner, where you can communicate with your compliance customer base and your employees. It would be best if you worked to incorporate one or more of the techniques to help you burn compliance into the DNA fabric of your organization.

Three key takeaways:

  1. Twitter can be a powerful tool for the compliance practitioner.
  2. Data mine Twitter for best practices and see what the regulators may be saying.
  3. Curiosity may have killed the cat, but it makes for a far better and more effective compliance practitioner.
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31 Days to More Effective Compliance Programs

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

Great Women in Compliance – Elaine Pretorius – The Sage Leader

Welcome to the Great Women in Compliance Podcast, hosted by Mary Shirley and Lisa Fine.

Elaine Pretorius is even more of an international citizen than Mary.  She shares her fascinating journey to today where she is a leader at McKinsey & Company’s Compliance function to the #GWIC audience.  Elaine gives some sage advice to listeners about implementing transformational change, being an extremely well-respected leader and diplomacy in the workplace.  Mary and Elaine shout out one of Elaine’s former team members, Melissa Lempa because they are huge fans of Melissa’s for being a true Great Woman in Compliance and legendary at her job.  Elaine shares some great personal anecdotes in this episode, join us to benefit from her wise advice.

You can find the Great Women in Compliance Podcast on the Compliance Podcast Network where you can find several other resources and podcasts to keep you up to date in the Ethics and Compliance world. You can also find the GWIC podcast on Corporate Compliance Insights where you can learn more about the podcast, stream prior episodes and catch up on Mary’s monthly column “Living Your Best Compliance Life.”

Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.  Don’t forget to send the elevator back down by passing on your copy to someone who you think might enjoy reading it when you’re done, or if you can’t bear parting with your copy, consider it as a holiday or appreciation gift for someone in Compliance who deserves a treat.

You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.

Join the Great Women in Compliance community on LinkedIn here.

Categories
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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Daily Compliance News

Daily Compliance News: May 16, 2023-the AI and Compliance Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you compliance related stories to start your day. Sit back, enjoy a cup of morning coffee and listen in 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 Include

  • Using AI to manage risk. (InsideBigData)
  • How will AI change the workplace. (WSJ)
  • Using AI to manage regulatory risk frameworks. (PYMNTS)
  • Will AI help compliance? (Forbes)