Tag: culture

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31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 11 – Moving Compliance Tone Down Through an Organization

The 2023 ECCP made it clear that a company must have more than simply good ‘Tone-at-the-Top’; it must move down through the organization from senior management to middle management and into its lower ranks. It stated, “Beyond compliance structures, policies, and procedures, it is important for a company to create and foster a culture of ethics and compliance with the law at all levels of the company. The effectiveness of a compliance program requires a high-level commitment by company leadership to implement a culture of compliance from the middle and the top.”

Employees often look to their direct supervisor to determine what the tone of an organization is and will be going forward. Many employees of large, multi-national organizations may never have direct contact with the CEO or even senior management. By moving the values of compliance through an organization into the middle, you will be in a much better position to inculcate these values and operationalize compliance with them.

Three key takeaways:

1. Tone at the top—direct supervisors become the most important influence on people in the company

2. Give your middle managers a toolkit around compliance so they can fully operationalize compliance

3. Organizational justice is an additional way to help operationalize compliance

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The ESG Report

The ESG Report – Christian Harris on Safety as The ‘S’ in ESG

The ESG Report podcast is hosted by Tom Fox. Looking for innovative solutions to tackle climate change? Look no further than The ESG Report! In this episode, Tom speaks with Christian Harris from Slip Safety Services on Safety as The ‘S’ in ESG

Christian Harris is a seasoned safety professional with over a decade of experience, specializing in slip and fall prevention. His passion for safety was sparked by a personal incident, leading him to advocate for the integration of safety measures in business operations. Harris believes that safety should not be viewed merely as a means to prevent accidents but as an enabler of culture, high performance, and profit. He coined the term “safety-nomics” to highlight the positive impact of safety on business performance and uses the success story of Alcoa to illustrate the correlation between a strong safety culture and improved business outcomes. Join Tom Fox and Christian Harris on this episode of the ESG Report as they delve deeper into the importance of integrating safety measures into business operations.

Key Highlights:

  • Safety Shifts and Compliance in Energy
  • The Transformative Power of Safety Integration
  • The Significance of Safety in Business Performance
  • Identifying Slip and Fall Factors in Consumer Businesses
  • The Importance of Proactive Safety Culture

Resources:

Christian Harris on LinkedIn

 Tom Fox 

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10 For 10

10 For 10: Top Compliance Stories For The Week Ending January 6, 2024

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings to you, the compliance professional, the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes, hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  1. Senator Menendez draws more charges. (CNN)
  2. Political protests are a compliance risk. (WSJ)
  3. Can the Big 4 ever govern themselves? (FT)
  4. SpaceX illegally fired workers for protected conduct. (NYT)
  5. Broader DEI fights are coming to the Boardroom. (NYT)
  6. Trump companies took in $7.8 in payments from foreign governments and officials. (WSJ)
  7. A suspended Altice office leaves the company. (Bloomberg)
  8. AML whistleblower programs will help in greater ABC efforts. (Bloomberg)
  9. Taking on the banking culture of drive fast, crash.(WSJ)
  10. How FEPA will change ACP enforcement.(WSJ)

You can check out the Daily Compliance News for four curated compliance and ethics-related stories each day here.

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Daily Compliance News

Daily Compliance News: December 14, 2023 – The Serious Misconduct 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 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 we are following in today’s edition:

  • Former BP CEO docked $40M for ‘serious misconduct’. (WSJ)
  • Why culture outside the US matters. (FT)
  • Tesla has a 2MM car recall. (BBC)
  • Hackers target outdated servers. (Reuters)
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Blog

Assessing and Improving Corporate Culture Through the Culture Audit™

I am hugely pleased to announce a dynamic new tool for compliance professionals, the Culture Audit™ which is a software tool designed to help companies evaluate their corporate culture and identify areas for improvement. Developed by Sam Silverstein, founder of the Accountability Institute, the Culture Audit™ allows a compliance professional or any business to assess their corporate culture quickly and efficiently as mandated by the Department of Justice (DOJ). (Full disclosure-I do work for and with Sam Silverstein and the Accountability Institute.)

Beginning with the speech by Deputy Attorney General Lisa Monaco in October 2021, the recognized the need for companies to assess, manage, monitor and improve their corporate culture. This was memorialized in the 2023 update to the Evaluation of Corporate Compliance Programs (ECCP), announced in January 2023. In the ECCP, the DOJ asks these 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 needs to assess their culture, because the DOJ is going to do in any enforcement action or review. However, it can be done using the same compliance processes currently in place, as culture is just like any other risk. As a risk, it can be assessed. This is why the Culture Audit™ is such a game-changer in compliance as it provides you a software tool to perform that initial risk assessment. When you have assessed a risk, then you can start to put together a risk management strategy in place. With your culture strategy in place, you can train your employees on it and then monitor their performance, determining the results. From there you can improve your culture strategy as needed. But it all starts with a culture assessment, and that’s what the Culture Audit™ allows you to do.

The Culture Audit™ can be set to 20 languages, which makes this the best possible tool, not just for international companies, with offices around the world, but also those in places like in South Dakota, where there might be a production facility and there could actually be three or four languages spoken on the production floor. This allows all employees in an organization the opportunity to communicate, to provide the vital feedback, and makes this a very powerful tool.

The Culture Audit™ is simple for all employees to use as a link is provided used throughout the organization. Moreover, it is an anonymous survey. The Culture Audit™ does collect any specific Personal Identifiable Information (PII). The Culture Audit™ does not know who is responding, and there is no ability to track back to individual employees. This provides an environment where employees are free to share what they really think about the organization, what they really feel about what’s happening inside in their workplace culture.

The Culture Audit™ measures various aspects of a company’s culture, including compliance practices, hiring processes, and employee engagement. It generates a comprehensive report that highlights gaps and provides actionable steps for improvement. The tool is particularly beneficial for global organizations as it supports international language communication.

One key feature of the Culture Audit™ is its emphasis on auditability and transparency. In the event of a regulator’s inquiry, the Culture Audit™ provides a detailed report that can be shared to demonstrate the company’s commitment to assessing and improving its culture. The questions and the results are fully auditable. The raw data collected during the audit is also retained for future reference, allowing organizations to track their progress over time.

One of the key benefits of the Culture Audit™ is its ability to identify areas for improvement and provide actionable insights. The Culture Audit™ report includes an action plan that guides organizations on specific areas to focus on and steps to take for improvement. Silverstein emphasized that all companies should be either improving because they are underperforming or reinforcing what they are already good at. By continuously reinforcing positive aspects of their culture, organizations can prevent a decline over time.

The Culture Audit™ can also be a valuable tool for companies considering acquisitions. By using the tool to assess the culture of a potential target, companies can gain insights into the target’s values, ethics, and decision-making processes. This information can help inform the decision-making process and identify potential risks or areas of alignment.

The Culture Audit™ is a true game-changer in compliance as it provides organizations with a powerful tool to assess and improve their corporate culture. By measuring various aspects of culture, providing actionable insights, and emphasizing auditability and transparency, the Culture Audit™ helps organizations create a positive and productive workplace environment. With the increasing focus on corporate culture by regulators, the Culture Audit™ can also help companies demonstrate their commitment to ethical behavior and compliance. By utilizing this tool, organizations can drive better leadership, improve employee engagement, and ultimately enhance their bottom line.

Resources

Culture Audit

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

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 17 – Improve Corporate Culture Through an Internal Podcast

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 to 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.

Podcasting is a powerful tool that corporate compliance programs can use to connect with their audience on a more personal level. By investing in podcasting, 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?

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

 Three key takeaways:

1. You can improve employee trust and corporate culture through employee trust.

2. Communicating through a podcast can increase your brand promise with employees and other stakeholders.

3. An internal podcast can humanize your leadership to your employees.

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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.