Tag: culture

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31 Days to More Effective Compliance Programs

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

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

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

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

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

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

 Three key takeaways:

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

2. Employees must be protected from retaliation.

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

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

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Blog

Improving Corporate Culture Through Podcasting

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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31 Days to More Effective Compliance Programs

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

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

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

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

 Three key takeaways:

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

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

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

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

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 13 – Preventing Retaliation to Improve Culture

Retaliation against a person who speaks up is a pervasive issue that not only creates a toxic work environment but also discourages victims from reporting incidents. This means you must address retaliation and encourage reporting in workplaces. When employees report harassment face severe retaliation, which leads to a loss of trust in the reporting process. This fear of being labeled a “rat” or “gossip” often prevents victims from coming forward and seeking justice. To combat this issue, non-retaliation protocols are crucial to protect individuals and ensure legal compliance.

Non-retaliation protocols must be in place to encourage reporting.  The fear of retaliation is deeply rooted in the perception of being a whistleblower or complainant. Every compliance must have strong policies, consequences for violators, and open workplace conversations to empower bystanders. Bystanders play a crucial role in identifying and reporting harassment, but they often fear retaliation or loyalty conflicts.

Addressing retaliation and encouraging reporting in workplaces requires a multifaceted approach. Strong non-retaliation protocols, open workplace conversations, and the empowerment of bystanders are key factors in creating a safe and inclusive work environment. By prioritizing the well-being of employees and fostering a culture of trust, organizations can effectively combat sexual harassment and ensure compliance with legal and regulatory requirements.

 Three key takeaways:

1. You must have robust policies and procedures against retaliation.

2. A lack of confidential reports will have an impact on culture.

3. Bystanders are the key to a robust culture.

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

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 10 – Improving Culture Through Investigations

Meric Bloch strongly emphasizes the importance of workplace investigations and fostering a culture of employee compliance. He believes that merely setting up a hotline and establishing policies is insufficient; companies must actively engage with employees to understand their motivations for speaking up or remaining silent. Bloch also underscores the need for accountability and a critical evaluation of the effectiveness of compliance programs. His experiences with multinational companies have shaped his understanding of the challenges they face, particularly the fear of being perceived as incompetent and the difficulties in reporting.

One of the key points raised by Bloch is the importance of making speaking meaningful and credible. He pointed out that companies often fail to communicate what should be reported, leading to confusion among employees. Bloch also highlights the lack of follow-up interviews and training for reporters as a problem. He stressed the need for organizations to engage with reporters and gather additional information to better understand the context and potential gaps in the initial report. Bloch also discussed the importance of addressing friction points within organizations. He mentioned that employees often hesitate to speak up due to concerns about the involvement of headquarters or fear of retaliation. Organizations must actively address these concerns and create an environment where employees feel safe and supported when reporting issues.

To create a culture of speaking up, organizations must move beyond passive measures such as hotlines and policies. They need to actively engage with employees, educate them about their role in the process, and provide clear guidance on what should be reported. By doing so, organizations can foster a culture of compliance where employees feel empowered to speak up and contribute to maintaining ethical standards.

Three key takeaways:

1. Your investigation process must go beyond simple policies and procedures.

2. Seeking additional information from a reporter will enhance the investigative process and your culture.

3. Remove friction points in the speak-up and investigative processes.

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

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 9 – Fostering Culture with Psychological Safety

How can you improve corporate culture through speaking up? In an MIT Sloan Management Review, Summer edition, entitled “Fostering Ethical Conduct Through Psychological Safety” authors Antoine Ferrère, Chris Rider, Baiba Renerte, and Amy Edmondson asked such questions as “How do organizations encourage people to speak up about ethical breaches, whether inadvertent or deliberate?” and “Why do some employees choose to remain silent when others report misconduct?” Additionally, they “analyzed the perceptions of those who report misconduct against those of “silent bystanders” to help “better understand both the drivers and derailers of speaking up — and revealed insights into how leaders and compliance officers can encourage employees to make such reports.’”

The authors believe today, “it is more essential than ever that when misconduct happens or difficult problems arise, there is a strong ethical climate for surfacing information so leaders can respond quickly and appropriately. An environment in which employees feel comfortable reporting such issues is also vital to preventing future misconduct.”

The authors believe that a “healthy organizational culture is one in which speaking up and listening go hand in hand, reinforcing ethical standards. If concerns are expressed, changes can be made promptly.” This is important because it moves from the detect prong to the prevent prong, which is by far the most important and effective prong in any compliance regime. Further ideas or innovations, rather than simply reporting untoward actions, can make a company more efficient and more profitable. This means a company can receive far more benefits than monetary fines or penalty avoidance if psychological safety exists.

 Three key takeaways:

  1. How a speak-up culture improves your culture.
  2. What is the role of psychological safety in improving culture?
  3. What is the role of externals in your corporate culture?

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

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 7- To Improve Culture, Engage More

One thing I have learned in working with Carsten Tams is that one of the very top keys to a successful compliance program is employee engagement. Tams and I explored this topic in the popular podcast series Design Thinking in Compliance. It also appears that attention can lead to excellent business resiliency based upon an article entitled The Top 10 Findings on Resilience and Engagement, by Marcus Buckingham.

Not surprisingly, trust is the number 1 factor in engagement and resilience. Astoundingly, the author found that “employees who said they completely trust their team leader were 14 times more likely to be fully engaged.” Moreover, those employees who completely trusted their colleagues, team leader, and senior leaders “were 42 times more likely to be highly resilient.” The reason should seem obvious as it is undoubtedly “easier to engage in our best work when we don’t have to expend mental resources looking over our shoulders or protecting ourselves against dysfunctional workplace practices that erode trust, like bullying or micromanaging. When it comes to building engagement and resilience, trust is everything.”

Teamwork is also a key factor. Although this is not something I have experienced over the past 12 years of working alone, the author found, “Those who said they are on a team were 2.6 times more likely to be fully engaged and 2.7 times more likely to be highly resilient than those who didn’t identify as team members. For millennia, humans have experienced psychological well-being only when they feel connected to and supported by a small group of people around them.” When the pandemic hit, working from home was not new to me as I had been doing it since 2010, but even in the WFH or Hybrid Work era, most employees need to feel like they are part of a team.

Every CCO and compliance professional must work to lessen or dissolve the disconnect between senior leadership and front-line workers. Your front-line business folks will make or break your compliance program. Getting your senior management more engaged will create and establish the trust your employees will need to show resilience in the face of the following primary business location, whether a pandemic or military invasion.

 Three key takeaways:

  1. The concepts from Design Thinking can improve your culture.
  2. A key factor in culture is engagement.
  3. You can improve culture by dissolving the disconnect between senior leadership and front-line workers.

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

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 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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GalloCast

Gallocast-Episode 12: Halloween and Day of the Dead

Welcome to the GalloCast. You have heard of the Manningcast in football. Now we have the Gallocast in compliance. The two top brothers in compliance, Nick and Gio Gallo, come together for a free-form exploration of compliance topics. It is an excellent insight on compliance brought to you by the co-CEOs of ComplianceLine. Fun, witty, and insightful with a dash of the two brothers throughout. It is like listening to the Brothers Gallo talk about compliance at the Sunday dinner table. Hosted by Tom Fox, the Voice of Compliance.

Halloween and Day of the Dead are just past us as the Brothers Gallo return for another Gallocast. Nick Gallo, in discussing SBF and FTX, emphasizes the importance of legal guidance and accountability in navigating complex ethical issues. He believes in the power of effective communication and strategic leadership in advocating for corporate ethics and compliance. On the other hand, Gio Gallo, with his focus on storytelling and advocacy, stresses the significance of securing budget allocation towards compliance and ethics from the executive suite. He believes a cultural shift within the organization involving a diverse group of individuals is crucial in addressing compliance and ethics challenges. Join Tom Fox, Nick Gallo, and Gio Gallo as they delve deeper into these topics in this episode of the GalloCast podcast.

Key Highlights:

  • SBF and Advice of Counsel defense. Where does the leadership buck stop?
  • RTW or WFH. How should an employer(s) approach this topic?
  • DS Disco- Why would 25% of the workforce write a letter to BOD asking them to fix corporate culture?
  • At what point should a start-up build out its internal controls? How about a compliance program?
  • How transparent should your whistleblowing process be with a reporter?
  • UM, the football program, is being investigated for electronic sign stealing.
  • What happens if a whistleblower allegation is made in bad faith?

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Tom Fox 

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