Tag: culture

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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 

Connect with me on the following sites:

Instagram

Facebook

YouTube

Twitter

LinkedIn

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 3 – Compliance and Corporate Principles in Today’s World

For corporations, navigating the political landscape has become an increasingly difficult task. While being admonished to ‘stay in their lane’ by some, businesses are just like their stakeholders, impacted by the ever-changing political miasma. When this new reality is coupled with the new levels of transparency in companies, which are only amplified by social media, a company can be embroiled in public controversies with one or more stakeholder groups. As these situations occur, CCOs and compliance professionals will be called upon to help companies navigate this fraught process.

How can compliance help a company navigate through all of this? To make and implement the best strategic choices in this environment, leaders will have to

  1. develop principles to guide strategic choices,
  2. address ethical issues early on,
  3. consistently communicate and implement their choices,
  4. engage beyond the industry to shape the context and
  5. learn from mistakes to make better choices in the future.

This is a process that the corporate compliance function can facilitate. If you work through these steps, you should be able to prepare your organization for the next major shock.

 Three key takeaways:

1. Why a company can no longer simply ‘stay in its lane’.

2. Compliance should lead the way to develop robust principles to guide cultural choices.

3. Even in culture, continuous improvement is a mandate.

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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 

Connect with me on the following sites:

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
GalloCast

GalloCast: Episode 11 – CEOs Behaving Badly

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 a great 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’s like listening to the Brothers Gallo talk compliance at the Sunday dinner table. Hosted by Tom Fox, the Voice of Compliance.

Football season returns to this brings another season of the GalloCast. Nick and Gio are both known for their outspoken nature and deep understanding of workplace dynamics, CEO-worker relationships, and ethical decision-making. Nick believes in the importance of ethical sourcing, labor and social responsibility, and community engagement in creating a beneficial workplace environment. He emphasizes the role of the compliance and ethics team in ensuring ethical practices and the balance between self-interest and the well-being of employees and stakeholders. On the other hand, Gio stresses the importance of authenticity and cultural change in improving workplace dynamics. He believes that a mere change in name or logo is not enough, there needs to be an authentic push by leadership to build a culture of integrity. Join Tom Fox and the Gallo brothers, Nick and Gio, on this episode of the GalloCast.

Key Highlights

·       Do workers need to see pain?

·       CEOs behaving badly. 2 top CEOs resign for having affairs with subordinates or outright harassment. Rubiales resigns.

·       Huge oil field discovered of Namibia. How should a company prepare?

·       SEC probes Musk corporate perks.

·       CBRE busted over pre-taliation. Why having the right contract language is important.

·       Will a name change for SNC-Lavalin help it overcome its corrupt past?

·       SCCE. What are you expecting?

 

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Tom Fox 

Connect with me on the following sites:

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Innovation in Compliance

Unlocking Success: The Crucial Role of Culture in Compliance: Part 5 – Alexander Cotoia on the Continuous Improvement of Culture

Welcome to a special series on building a stronger culture of compliance through targeted and effective training sponsored by Diligent. I will visit with Yvette Hollingsworth-Clark, Viktor Culjak, Jessica Czeczuga, Michael Parker, and Alexander Cotoia in this series. Over this series, we will consider what culture is, how to assess culture, putting together a strategy to manage culture based upon this assessment, monitoring that strategy in the future, and using information from your monitoring to improve your culture continuously. In this concluding Part 5, we visit with Alexander Cotoia to discuss a strategy to enhance your compliance program in the future constantly.

Alexander Cotoia, a regulatory compliance manager and consultant at the Volkov Law Group, has a rich background in commercial litigation and has spent a significant part of his career in an in-house role at Virgin Galactic. Alexander strongly emphasizes the importance of compliance culture in organizations, believing that a culture promoting compliant behavior reduces the likelihood of ethical lapses or legal violations. He argues that creating a culture of compliance is not only ethically sound but also makes good business sense in today’s era, where consumers are well-informed and employees prioritize alignment with organizational values. Alexander suggests that organizations should reinforce their values and highlight the economic benefits of compliance to gain employee buy-in and engagement, emphasizing the need for continuous improvement, conducting root cause analysis, and involving various stakeholders to address cultural issues effectively. Join Tom Fox and Alexander Cotoia as they dive deep into how to continuously improve your compliance program in this episode of Unlocking Success: The Crucial Role of Culture in Compliance Best Practices podcast episode.

Key Highlights: 

  • Cultivating CEO Involvement for Compliance Success
  • Improving Corporate Culture through Effective Monitoring
  • Cultivating Compliance Culture through Stakeholder Collaboration

Ready for Purpose-Driven Compliance? Diligent equips leaders with the tools to build, monitor, and maintain an open, transparent ethics and compliance culture. For more information and to book a demo, visit Diligent.com.