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Culture Crafters

Culture Crafters: Assessing Your Culture Through The Culture Audit™

It is always interesting to see the regulators catch up to the business world. That is what has happened around corporate culture. The Department of Justice is now assessing corporate culture for any company under investigation. Yet more than simply complying with this mandate, companies should strive to foster the best culture they can. The reason is deceptively simple: the better the culture, the better the company. But many business executives and even compliance professionals do not know how to craft a culture that allows your employees and, thereby, your organization to implement such strategies. How can you unlock the power of a thriving workplace culture?

In this podcast series, Sam Silverstein, the most trusted voice in America on accountability  and Tom Fox, the Voice of Compliance, look at the ways companies can elevate their culture to new heights.  In this inaugural episode, they discuss how to assess your culture through the Culture Audit™.

The concept of a culture audit is a transformative tool that assesses an organization’s critical areas such as ethics, engagement, accountability, and diversity, offering valuable insights for improvement and fostering a high-performance work culture.

Tom posits that the culture audit not only measures these critical areas but also guides action plans for improvement, emphasizing continual assessment and prioritization of key cultural drivers for genuine change.

Similarly, Sam Silverstein underscores the necessity of conducting a culture audit to discern an organization’s cultural strengths and weaknesses. He asserts that culture directly affects an organization’s bottom line, citing instances where cultural improvements have significantly boosted performance, profits, and employee retention. For Silverstein, a comprehensive culture audit from the boardroom to the shop floor is fundamental for developing a positive and high-performing work environment.

Key Highlights:

  • Enhancing Organizational Culture for High Performance
  • Cultivating Accountability and Excellence for Success
  • Enhancing Workplace Culture through Detailed Assessment
  • Transparent and Traceable Culture Audit Findings
  • High-Performance Culture: Driving Financial Success

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

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Blog

Auditing Culture

Why should you audit your culture? A compliance professional can utilize a comprehensive approach to evaluate various aspects of a company’s culture, including ethics, engagement, accountability, and diversity. Tom Fox and Sam Silverstein took up this topic in the inaugural episode of the Culture Crafters podcast. Silverstein emphasized the pivotal role of a high-performance culture in attracting and retaining top-tier talent, ultimately leading to improved company performance and profitability. According to Silverstein, the shortest and quickest path to organizational transformation is through culture, as it forms the core of all change.

Beginning with the speech by Deputy Attorney General Lisa Monaco in October 2021, they recognized the need for companies to assess, manage, monitor, and improve their corporate culture. This was memorialized in the 2023 Evaluation of Corporate Compliance Programs (ECCP) update, announced in January 2023. In the ECCP, the DOJ asks the following questions: how often and how does a company measure a culture of compliance? What are your hiring and incentive structures around compliance? What steps have you taken in response to your measurements of compliance?

All these questions posed by the DOJ lead to the requirement that every company assess its culture because the DOJ will take any enforcement action or review. However, it can be done using the same current compliance processes, as culture is just like any other risk. As a risk, it can be assessed. This is why a culture audit is a necessary first step in determining where your culture is, what needs improvement, and how to do so.

As important as it is to meet these DOJ expectations, the real power is to create a high-performing culture to allow your organization to grow to its potential. Focusing on a high-performance culture can lead to an 80% increase in performance, profits, and employee retention, fostering a productive work environment and driving overall success. The bottom line is that a high-performance culture is essential for attracting and retaining top-tier talent and can significantly improve a company’s performance and profitability.

Every compliance professional understands that you must first assess your risks in risk management. When you have assessed a risk, you can start to put together a risk management strategy. The same is true for corporate culture. You must first assess where your culture is and then move forward to improvement through culture and a culture management strategy. With your culture strategy in place, you can train your employees and monitor their performance, determining the results. From there, you can improve your culture strategy as needed. But it all starts with a culture audit.

The steps are familiar to every compliance professional.

  1. Assess Every Level. To gain a comprehensive understanding of the company’s culture, you must assess everyone in the organization, not just senior leadership.
  1. Continuous Improvement. After conducting the culture audit, organizations must receive a detailed Culture Audit Report, which includes responses and action plans. This report serves as a roadmap for companies to focus on key drivers, enhance alignment, and continuously improve their workplace culture.
  1. Sustain High Performance. Focus on building a high-performance culture can yield remarkable results, including an 80% increase in performance, profits, and employee retention. Creating a culture that inspires individuals to excel and be accountable is essential for long-term success.

To facilitate this, Silverstein created Culture Audit™. The Culture Audit is a software solution that assesses critical areas of a company’s culture, such as ethics, engagement, accountability, and diversity, providing actionable insights for improvement. Available in over 20 languages, it aids in transforming a company’s culture for sustainable high performance. A high-performance culture is essential for attracting and retaining top-tier talent and can significantly improve a company’s performance and profitability. The Culture Audit Report, a detailed document with responses and action plans, enables organizations to enhance their workplace culture effectively. The audit results are auditable, ensuring accurate conclusions and data traceability, adding credibility to the process. Focusing on a high-performance culture can lead to an 80% increase in performance, profits, and employee retention, fostering a productive work environment and driving overall success.

Silverstein encapsulates the essence of culture transformation: “The shortest, quickest path to seeing transformation in an organization is always through the culture because that’s at the core of all transformation.” Every business is incumbent upon preparing a comprehensive document that takes a deep dive into its culture assessment results and guides it on the path to improvement. This report is a foundation for implementing educational initiatives, training programs, and organizational transformation.

In conclusion, the culture audit is not a one-time fix but a continuous process that requires regular assessment and improvement. By prioritizing a high-performance culture, companies can create a productive work environment, attract top talent, and drive overall success.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance: Episode 19 – The Holiday Edition

What happens when two top compliance commentators get together? They talk about compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode! In this episode, Tom and Kristy take on a wide variety of topics, including Florida Man’s Booty Patrol.

In the ever-evolving world of regulatory compliance and risk management, challenges are constant and strategies must be dynamic. Tom highlights recent SEC pronouncements on culture and takes a look back at Serpico and the Salt Lake City Olympic scandal. Kristy highlights AI regulation in the EU and US, talks about the need for employees to have some time off, and checks in on Florida Man. Join Tom Fox and Kristy Grant-Hart as they delve deeper into these issues in this episode of the 2 Gurus Talk Compliance podcast.

Highlights Include:

  1. SEC Chief Accountant on what bothers him. (WSJ)
  2. Using onboarding as a corporate culture set. (FCPA Blog)
  3. Serpico at 50. (The Guardian)
  4. Salt Lake City Olympic corruption scandal, 25 years later. (Salt Lake Tribune)
  5. Carrot and Stick in new M&A Safe Harbor (Compliance and Enforcement)
  6. SEC Kicks Climate Rule to 2024 (Radical Compliance)
  7. In Landmark Vote, Europe Approves AI Regulations–Paving the Way for U.S. Adoption (Inc.com)
  8. SEC Head Warns Against ‘AI Washing,’ the High-Tech Version of ‘Greenwashing’ (WSJ)
  9. Employees Need Time Off. Here’s How to Craft a Successful Policy. (Bamboo HR)
  10. Florida man faces charges after driving ‘BOOTY PATROL’ truck (ClickOrlando News)

 Resources: 

Kristy Grant-Hart on LinkedIn

Spark Consulting

Tom

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FCPA Compliance Report

FCPA Compliance Report -The Culture Audit™ for Culture Assessments

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes Sam Silverstein to talk about the new software product, The Culture Audit™ which allows a compliance professional to perform a culture assessment as required by the Department of Justice.

In the ever-evolving corporate world, the importance of assessing and improving corporate culture cannot be overstated. This is the focus of The Culture Audit™, a software tool that provides a comprehensive assessment of a company’s culture, identifying potential risks and areas for improvement, developed by Sam Silverstein and the Accountability Institute. Tom views The Culture Audit™ as a valuable tool, especially in light of the Department of Justice’s focus on corporate culture in white-collar enforcement actions. He sees culture as a risk that can be assessed, managed, and continuously improved.

Sam shares this perspective and with his extensive experience in accountability and leadership, he emphasizes the importance of regular culture assessments, which can lead to a better bottom line by fostering a culture of high ethics, employee engagement, and quality decision-making. To learn more about the Culture Audit and how it can benefit your organization, join Tom Fox and Sam Silverstein on this episode of the FCPA Compliance Report podcast.

 Key Highlights

  • Culture Assessment and Risk Identification Tool
  • Multilingual Communication Tool for Global Organizations
  • Creating a Data-Driven Workplace Culture
  • The Culture Audit™: Assessing and Improving Workplace Culture
  • Measuring Relational Commitments for Organizational Success

Resources

Culture Audit

Set up a call to discuss the Culture Audit, click here

Sam Silverstein and the Accountability Institute

Sam Silverstein on LinkedIn

 Tom Fox

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FCPA Compliance Report

Compliance Lessons from Venice – Arsenale and Corporate Culture

In Part 2 of this special 3-part series, we continue our look at compliance lessons from Venice by reviewing the Arsenale and corporate culture. The Arsenale district in Venice, a significant maritime hub from the mid-1200s to mid-1400s, serves as a fascinating historical example of compliance program implementation. The district was renowned for its innovative shipbuilding techniques, which were zealously guarded as state secrets through strict regulations and severe punishments for violators.

Tom draws parallels between the practices of the Arsenale district and the guidance provided by the DOJ and SEC. He emphasizes the importance of a balanced approach to compliance, incorporating both incentives and discipline. Fox suggests that companies should provide job security, compensation for mishaps, and assistance to families as incentives for employees to remain loyal and compliant, while also using financial rewards, promotions, and acknowledgments as effective tools for driving corporate culture. Join Tom Fox on this episode of the Compliance Lessons from Venice podcast as he delves deeper into the lessons that can be learned from the Arsenale district’s historical example.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 5 – Redesigning Culture

How can you think through a different way to redesign your culture and compliance program based on an article in MIT Sloan Management, entitled The Four-Step Process for Redesigning Work by Lynda Gratton? Gratton believes that a “fear of failure weighs heavily on many leaders tasked with managing new workplace expectations. Seeing the challenge as a process is the way forward.” Her piece provides a great way to think about the decision on hybrid or other models of working going forward.

Understand What Matters

Reimagine new ways of operating

Model and test new ways of working

Act and create

Gratton ended her piece by challenging leaders to ask themselves three questions: “Where are you now on the journey of redesigning work? Are there steps you need to reengage in a more purposeful manner? Are you clear about what your biggest priorities are? The actions you take now will create your signature model of work and define the deal that you are making with your employees and your customers.” The same is even more so for a Chief Compliance Officer, the corporate compliance function and culture.

 Three key takeaways:

1. How to think through redesigning your culture.

2. Understand what matters to your employees.

3. Listen, listen, listen.

Check the free webinar on the new tool, The Culture Audit with Tom Fox and Sam Silverstein on Monday, November 20, 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 4 – Assessing and Aligning your Corporate Values

One of the concepts enshrined in the Monaco Memo is that the Department of Justice (DOJ) will assess corporate culture for any company that may find itself under investigation for Foreign Corrupt Practices Act (FCPA) violations. This enshrinement is not exactly new as Deputy Attorney General (DAG) Lisa Monaco announced this new DOJ focus in October 2021 in her speech. The parameters of how the DOJ will assess culture are still being worked out but Chief Compliance Officers (CCOs) and compliance professionals need to consider this issue in the context of their own compliance programs and corporate culture in case the DOJ ever comes knocking. Over the next several blog posts, I will be exploring how a corporate compliance function can assess, monitor, and improve your corporate culture.

We begin with assessing your corporate values and then aligning them within your organization. In a recent Harvard Business Review (HBR) article, entitled What Does Your Company Really Stand For?authors Paul Ingram and Yoonjin Choi explored these and other issues. The authors believe that corporate values are more critical than ever. I have adapted their work for the compliance professional.

The authors developed a five-step approach for values alignment.

1.     Identify the values within your employee base and create a values structure.

2.     Identify key priorities from strategy to determine what is the most important thing the organization can do to achieve its strategy.

3.     Wed values that serve both the organization and its employees.

4.     Begin the assessment process.

5.     Generate a final list of organizational values.

From the compliance perspective, the protocol. Recognizing that values are but one part of an overall corporate culture, gives you a mechanism to think through how to begin an overall assessment of your organization. Values do make up a portion of an overall culture. Through the engagement advocated herein, you can not only get a good reading on such key values as trust and respect but, more importantly, learn how to incorporate them as overall assets into your corporate culture.

Three key takeaways:

1. The Monaco Memo enshrined the concept that the DOJ will assess culture.

2. What does your company stand for?

3. When properly aligned, values can be a powerful part of corporate culture.

Check the free webinar on the new tool, The Culture Audit with Tom Fox and Sam Silverstein on Tuesday, November 20, 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 2 – Getting Culture Right

Vin DiCianni, founder of Affiliated Monitors, Inc. (AMI), talked about the Monaco speech and culture. He said, “The announcement by Deputy Attorney General Lisa Monaco and the Justice Department reignited the agency’s concentration of corporate liability for white-collar crimes. In doing so, she emphasized to businesses, their leadership, and the lawyers representing them how important it is to implement and maintain strong, effective compliance programs and how DOJ will con. In other words, the criticality of culture is now paramount. CCOs must focus on growing corporate culture to build the ethical foundation for a successful compliance program.

In the most recent MIT Sloan Management Review issue, Donald Sull and Charles Sull penned an article entitled “10 Things Your Corporate Culture Needs to Get Right”, in which they posited that “knowing what elements of culture matter most to employees can help leaders foster engagement as they transition to a new reality that will include more remote and hybrid work.” It is an excellent review of some of the key elements of corporate culture and how CCOs can move forward to lay the foundation of one.

CCOs and compliance functions face challenges while navigating the post-COVID-19 return to work. According to the DOJ’s regulations, businesses must uphold a healthy culture through corporate culture. The authors conclude, “Understanding the elements of culture that matter most to employees can help leaders maintain employee engagement and a vibrant culture as they transition to the new normal.”

Three key takeaways:

1. What distinguishes a good corporate culture from a bad one in the eyes of employees?

2. A good corporate culture forms the basis of a good compliance program.

3. How many elements of a good corporate culture are in your organization?

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31 Days to More Effective Compliance Programs

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

In her October 2021 speech, presaging the Monaco Memo, Deputy Attorney General Lisa Monaco talked at length about the importance of corporate culture. She noted, “Corporate culture matters. A corporate culture that fails to hold individuals accountable or fails to invest in compliance — or worse that thumbs its nose at compliance — leads to bad results. Let me also be clear: a company can fulfill its fiduciary duty to shareholders and maintain a commitment to compliance and lawfulness. Companies serve their shareholders when they proactively place compliance functions and spend resources anticipating problems. They do so both by avoiding regulatory actions in the first place and receiving credit from the government. Conversely, we will ensure the absence of such programs inevitably proves a costly omission for companies who end up the focus of department investigations.” These thoughts were formalized in the Monaco Memo.

What does all this mean for compliance professionals going forward? DOJ officials have emphasized that the changes laid out in the Monaco Memo and the requirements around CCO Certification are to empower compliance professionals. In the Monaco Speech, DAG Monaco stated, “Companies should feel empowered to do the right thing—to invest in compliance and culture and to step up and own up when misconduct occurs. Companies that do so will welcome the announcements today. For those who don’t, however, our Department prosecutors will be empowered, too—to hold accountable those who don’t follow the law.” However you may characterize it, I will channel my inner Glenn Fry (with a nod to Miami Vice) and simply say to CCOs and compliance professionals, “The Heat is On.”

Three Key Takeaway:

  1. The DOJ will now evaluate corporate culture in an enforcement action.
  2. You must assess, manage, monitor, and improve your culture.
  3. Corporate culture is now a key metric for regulators.
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Daily Compliance News

Daily Compliance News: October 30, 2023 – The From $65 to $5 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 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:

  • Is crypto financing terrorism?  (NYT)
  • Suits against A&F begin. (WSJ)
  • What is the cost of a toxic culture? (WSJ)
  • Qatargate: Murky Prosecution? (DW)