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Innovation in Compliance

Unlocking Success: The Crucial Role of Culture in Compliance: Part 3 – Jessica Czeczuga on Creating a Strategy to Manage 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. 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 Part 3, we visit with Jessica Czeczuga on how to develop a strategy to manage your culture risk.

Jessica Czeczuga is a seasoned professional with over two decades of experience in training and development, specializing in areas such as finance, quality, compliance and ethics, leadership, and communication training. Jessica brings a unique perspective to the compliance space, emphasizing the pivotal role of managers in shaping and reinforcing company culture. She believes that managers, the most influential group within an organization, should be adequately trained to align with the desired culture and equipped with the necessary tools to communicate and reinforce cultural values effectively. Jessica also advocates for collaboration between compliance professionals and HR to improve culture, leveraging their counseling skills and creating clear processes for reporting and addressing culture-related issues. Join Tom Fox and Jessica Czeczuga as we dive deeply into this topic in this Unlocking Success: The Crucial Role of Culture podcast episode.

Key Highlights: 

  • The Impact of Managers on Company Culture
  • Collaborative Partnership: HR and Compliance Driving Reporting
  • The Role of Managers in Shaping Culture

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.

 Join us tomorrow, where we consider how to monitor culture going forward.

Categories
Innovation in Compliance

Unlocking Success: The Crucial Role of Culture in Compliance: Part 2 – Viktor Culjak on Assessing 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 Part 2, we visit with Viktor Culjak to discuss assessing culture.

Viktor Culjak is a chartered accountant with a strong finance, audit, and risk consulting background. Currently serves as the Director of Customer Success and Services at Diligent. With a decade of experience in the Big Four and a focus on governance, risk, and compliance (GRC) objectives, Viktor firmly believes in assessing and managing organizational culture as a risk factor. He views culture as a dynamic risk that can have significant consequences if not properly managed and advocates for standardized and benchmarked culture assessments to provide valuable insights for risk management. Viktor emphasizes the need for practical guidance on implementation, highlighting the significance of tone at the top and other artifacts such as policies, procedures, and feedback mechanisms in culture assessments. Join Tom Fox and Viktor Culjak as we delve deeper into assessing culture on this episode of the Unlocking Success: The Crucial Role of Culture podcast.

Key Highlights: 

·      Assessing and Auditing Organizational Culture

·      Creating a Culture of Effective Communication

·      Evaluating Culture Alignment for Continuous Improvement

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

 Join us tomorrow, where we consider how to create a culture management strategy.

Categories
Innovation in Compliance

Unlocking Success: The Crucial Role of Culture in Compliance: Part 1 – Yvette Hollingsworth – Clark on What is 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 Part 1, we ask what culture is with our special guest, Yvette Hollingsworth-Clark.

Yvette Hollingsworth-Clark, a seasoned professional in the financial services industry, currently holds the position of Chief Compliance Officer for State Street Corporation. With a robust background in risk management, Yvette has cultivated a deep understanding of the significance and measurement of corporate culture in the financial sector. She asserts that corporate culture should not be solely managed by the compliance function but rather owned by the C-suite and executed in various forms. Yvette emphasizes the need for specific metrics to monitor and promote desired cultural values, such as integrity. She believes culture can be measured through metrics such as the number of risk decisions overruled, challenged, or implemented correctly. She also highlights the importance of considering stakeholders such as customers, clients, and third parties when assessing corporate culture. Join Tom Fox and Yvette Hollingsworth-Clark on this episode to delve deeper into this topic.

Key Highlights:

  • Measuring and Managing Corporate Culture in Finance
  • Shaping Corporate Culture: Board’s Key Role
  • The Nuances of Assessing Organizational Culture

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

Join us tomorrow, where we consider how to assess your culture.

Categories
Report from IMPACT 2023

Report from IMPACT 2023: Nick Gallo on Generational Change in the Workplace and Importance of Culture

ECI’s IMPACT 2023 was one of the leading compliance events in 2023. At this conference, Tom Fox, the Voice of Compliance, was able to visit with several of the speakers, exhibitors, participants and one group of ethically minded Girl Scout Troop. In this limited podcast series, Report from IMPACT 2023, Tom explores many of the most cutting-edge topics in ethics and compliance through short podcast episodes. Check out the full series of interviews. You will be enlightened, informed and come away with a fuller and more thorough understanding of the most cutting-edge topics in ethics and compliance. In this episode, Tom visits with Nick Gallo, co-CEO at Ethico and Keynote speaker at Impact 2023. He and Tom talk about the themes from Nick’s Keynote.

Nick Gallo brings a wealth of experience from his background in private equity to the discussion of the changing landscape of work, ethics and culture. Gallo’s unique insights are shaped by his belief that traditional hierarchical structures in workplaces have been replaced with more flat and remote structures, presenting a significant opportunity for industry transformation. Drawing from his firsthand experience during his PE acquisitions and mergers career, he emphasizes the critical role of authentic culture in enhancing employee engagement and performance. Gallo also highlights the need for aligning personal values with the purpose of an organization, a concept he believes is lacking in today’s transactional economy. Join Tom Fox and Nick Gallo as they delve deeper into these insights on this episode of the Report from Impact podcast.

 Highlights Include 

·      The impact of culture in M&A

·      The role of ethics in the workplace

·      A new generation in the workforce

 Resources 

Nick Gallo on LinkedIn

Ethico

ECI

Categories
Daily Compliance News

Daily Compliance News: August 10, 2023 – The Leaving China Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All, from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

  • Dentons leaving China. (NYT)
  • Biden Administration bans investment in Chinese tech. (WSJ)
  • Kellogg cereal workplace attacked as ‘woke.’ (Reuters)
  • Eradicating toxic team behavior. (FT)
Categories
Blog

HR’s Key to Unveiling the True Ethical Fabric of Organizations

Compliance professionals understand the importance of fully operationalizing compliance and embedding it into the fabric of a business. How can your Human Resources (HR) function help to both create and maintain an ethical culture at your organization? It turns out in a variety of ways. Obviously significance of incentives in driving ethical behavior cannot be forsaken but there are other areas to consider such as the impact of cross-cultural differences on ethical behavior. HR can play a role in the importance of creating a speak-up culture where employees feel comfortable reporting ethical concerns without fear of retaliation.

In a world where ethics are paramount, HR professionals hold the key to creating an ethical culture within organizations. But what happens when change is pushed too quickly, compensation drives behavior, and cross-cultural differences come into play? Discover the challenges and secrets to success in this thrilling journey of HR’s quest for an ethical culture…

In the pursuit of understanding the vital role of HR in establishing an ethical culture, I stumbled upon an unexpected revelation that shook the very foundation of my beliefs. It was a twist that challenged my assumptions and left me with a burning question: Can change truly be achieved without sacrificing ethical values? As I ventured deeper into this journey, I uncovered unsettling truths about the underlying ethos of corporations and the detrimental impact of short-term targets. But what I discovered next was even more astonishing, a revelation that would forever alter my perspective on the role of HR in creating an ethical culture…

If you are feeling frustrated and overwhelmed because your efforts to create an ethical culture are being undermined by inconsistent enforcement and lack of accountability, then you are not alone! Despite implementing compliance programs and promoting ethical values, you may find that employees still engage in unethical behavior due to a lack of consequences or clear guidelines. This can lead to a sense of disillusionment and hinder the progress towards an ethical work environment.

HR significantly contributes to embedding ethical behavior within the organizational culture. By creating a conducive environment that promotes honesty and integrity, HR can foster a culture that this significantly resistant to unethical practices. It’s primarily up to HR to ensure that employees feel comfortable voicing concerns without fear of retaliation, helping to enhance the ethical culture within organizations.

The path to cultivating an ethical culture is often met with significant roadblocks such as too much rapid change, reward-driven behaviors, and cross-cultural conflicts. These elements can create an environment where unethical behavior thrives, impacting organizational growth and success. For a moral culture to strive, these challenges should be identified and effectively addressed, paving the way for a workplace that values ethical conduct.

Understanding the underlying organizational dynamics is crucial in establishing and maintaining an ethical culture. It’s not enough just to have a written code of conduct; the actual behaviors within the organization need to be assessed and aligned with these ethical guidelines. HR plays a crucial role in comprehending these dynamics, ensuring that metrics used to reward employees promote ethical conduct rather than encouraging unethical short-term success.

Have you ever heard these myths about the role of HR in creating an ethical culture? First myth: HR is solely responsible for ethical behavior. Second myth: Creating an ethical culture is too time-consuming and costly. Third myth: HR can’t effectively enforce ethical standards. But what if I told you that these myths are far from the truth? Some key points are:

  • How HR can be the key instigator in shaping an ethically driven business culture.
  • Recognizing the potential roadblocks that could obstruct the path to ethical behavior in organizations and how to overcome them.
  • Appreciate the crucial interplay between organizational dynamics and ethics.
  • Perceive the nuanced impact of incentives on ethics and how it can steer the moral compass in corporate environments.
  • Master the art of endorsing.

My journey into understanding the vital role of human resources in establishing an ethical culture within an organization started with a deep dive into the role of HR and how those roles could that shed light on a fundamental dilemma for compliance. This dilemma was not about right and wrong, but about navigating clashing interests, misaligned incentives, and conflicting cultures. I learned that pushing too much change from the top, too quickly and too frequently can warp a company’s ethical climate. This realization led me to critically analyze the compensation plans in various organizations. The stark reality that people do what they are rewarded to do underlyes ethos of many corporations. This means that short-term targets often overshadowed long-term success, leading to a detrimental impact on the ethical culture. As I delved deeper into the concept of ethical culture, I realized that the essence of this term is far more profound and complex than it seems on the surface. This is not just about formal corporate governance documents or written codes of conduct. It is about understanding and adopting your organization’s underlying culture. It is also about self-awareness, organizational awareness, and the courage to speak up. One problem is that too many leaders tended to seek advice from their like-minded peers rather than embracing diverse opinions. This convinced me about the importance of fostering a speak up culture, and most crucially, a culture devoid of retaliation. This exploration underscored the pivotal role of HR in championing ethical norms, thereby establishing a robust and effective compliance program.

Categories
31 Days to More Effective Compliance Programs

One Month to More Effective HR in Compliance: Day 2 – The Role of HR in Creating an Ethical Culture

Welcome to the August edition of One Month to a More Effective Compliance Program. In the month of August, 2023 we will consider the role of Human Resources in a best practices compliance program.

Creating an ethical culture in the workplace is essential for any business. Not only does it ensure that employees are making the right decisions, but it also helps to protect the company from potential legal and financial repercussions. But how do you create an ethical environment?

HR can play a key role in this process. They can provide employees with the tools and resources they need to make ethical decisions, such as a personal network for informal guidance and the opportunity to consult with advisory functions. Additionally, HR should support employees who want to do the right thing and ensure that those who speak up are not discriminated against or held back from promotion.

Written protocols are also important for the detection and prevention of unethical behavior. Companies should consider if their compensation system is based on performance or something else, and ensure that incentives are not driving behaviors that are counter to long-term success. Bonus payments and executive share schemes should not be based on short-term business metrics, and cross-cultural differences should be taken into account.

Leadership also plays an important role in creating an ethical culture. Senior leadership should set the tone from the top and reward ethical behavior, while also seeking out diverse opinions and breaking down silos in the corporate organization. Additionally, a speak-up culture should be encouraged to ensure that unethical behavior is not tolerated.

Finally, employees need to understand the organization’s underlying culture in order to make ethical decisions. Companies should ensure that employees have the tools and resources they need to make informed decisions, and that they are not pushed too much change from the top, too quickly and too frequently.

Creating an ethical culture in the workplace is essential for any business. By utilizing HR, written protocols, and leadership, companies can ensure that employees have the tools and resources they need to make ethical decisions. This will help to protect the company from potential legal and financial repercussions, while also creating an environment where employees feel supported and empowered to do the right thing.

Three key takeaways:

  1. Beware of the three obstacles to creating an ethical culture.
  2. What really matters in your company?
  3. A speak up culture will improve the operational performance of your business.

For more information, check out The Compliance Handbook, 4th edition, here.

Categories
GalloCast

Gallocast – Episode 10 – The Seven Year Anniversary Edition

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.

This podcast episode focuses on the importance of proper oversight and diligence when it comes to CCOs and other corporate leaders. The discussion highlights the implications of the Supreme Court’s ruling on diversity hiring, the need for internal controls implementation, the potential of ESG investment ROI, the consequences of unethical behavior, and the need for Deutsche Bank to address its culture of ethics. This episode emphasizes the need to create a culture of compliance and oversight within organizations in order to protect against fraud and mismanagement.to navigate these challenging issues in the corporate world. Tune in to GalloCast now!

Key Highlights

  • FTX CCO charged
  • Diversity after Supreme Court. Is it still important?
  • At what level should you apply DD to new hires? Executive level or something else
  • ESG-positive or negative for shareholders
  • BOA follows Wells Fargo with a fake accounts scandal.
  • KPMG caught cheating in The Netherlands
  • Deutsche Bank fails to meet DPA requirements.

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
FCPA Compliance Report

FCPA Compliance Report – Measuring Ethical Culture & Compliance Training Impact

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In the latest episode of FCPA Compliance Report, Tom Fox speaks with Parijat Jauhari and Susan Divers, both with LRN, about their new tool, Catalyst Reveal, which helps compliance professionals deal with the new DOJ requirements around culture assessment, risk management, monitoring, and improvement. They explain how Catalyst Reveal goes beyond traditional methods of measuring the effectiveness of compliance training and that the platform includes completion data, culture data, and learner sentiment analysis to determine training effectiveness.

They also discuss the importance of benchmarking, which allows for easy comparison of clients within the same industry and revenue band. Plus, find out about their upcoming additions to their product and how they can provide solutions to challenges posed by the Department of Justice. Tune in now to discover how Catalyst Reveal can help compliance professionals fulfill their obligations under the 2023 Evaluation of Corporate Compliance Programs. 

Key Highlights

·      Measuring Ethical Culture

·      Enhancing Compliance Training Effectiveness

·      Challenges in measuring training impact

·      Data Analytics in Compliance Training

·      Benchmarking and Data-driven compliance training

Notable Quotes

“This is the most exciting development in this space in all the time that I’ve been working in ethics and compliance because it allows companies and chief ethics and compliance officers and their teams to move beyond what I would call dead data.”

“The culture pulse survey that we’ve included in this which is the ethical culture pulse survey. That’s its full title. It asks questions in real time about levels of engagement from the employee base and levels of respect levels of transparency, levels of organizational justice. And that that is a breakthrough.”

“What this tells you is it goes beyond we had a  warm seat. for this training to say, we had people take it, and a lot of people in this group really struggled with facilitation payments or with what is an actual conflict of interest. And this is an area that compliance officers really struggle with.”

“We are really using some new technology, machine learning to mine the data because it’s you’re accumulating it every day that employees are actually.”

Resources

Parijat Jauhari on LinkedIn

Susan Divers on LinkedIn

LRN

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
GalloCast

GalloCast – Episode 9, Live at ECI

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 into compliance brought to you by the co-CEOs of Ethico. 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.

In this episode of the GalloCast, the trio discusses some of the most challenging issues companies face regarding ethics and compliance. They start by diving into the recent $767 million fine slapped on British American Tobacco for colluding to sell cigarettes into North Korea, violating sanctions. They debate who should be held accountable for changing a company’s culture, how deep-rooted biases can affect decision-making, and the effectiveness of regulatory enforcement. The discussion covers the intricacies of ethics in different business models, including distributor and commissioned sales agent models. They also discuss the risks and benefits of a conservative approach and the adaptability of ethics and compliance programs.  The episode concludes by discussing cultural fit in mergers or acquisitions and how finding common ground and preserving distinctness can be accomplished. Don’t miss out on the wealth of insights and practical advice on navigating these challenging issues in the corporate world. Tune in to GalloCast now!

Key Highlights:

  • BAT’s illegal sales to North Korea
  • Determining Right and Wrong in Corporate Decisions
  • Balancing Values and Profit in Business
  • Balancing Compliance and Ethics Programs
  • Adapting Ethics & Compliance Programs
  • Ethics and Compliance Teams in Companies
  • Dangers of Groupthink in Decision-Making
  • Culture’s Role in Business Mergers and Acquisitions
  • Cultural Integration in Mergers & Acquisitions

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Tom Fox 

Connect with me on the following sites:

Instagram

Facebook

YouTube

Twitter