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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.

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Leveraging Technology for Culture Monitoring

Welcome to a special five-part blog series on building a stronger culture of compliance, sponsored by Diligent. In this series I will visit with Yvette Hollingsworth-Clark, Viktor Cuijak, Jessica Czeczuga; Michael Parker; and Alexander Cotoia. In this series, we will consider what is culture, how to assess culture, putting together a strategy to manage culture based upon this assessment, the monitoring of that strategy going forward and using information from your monitoring to engage in continuous improvement of your culture.

Many compliance professionals struggle with the ‘softness’ of culture. However, properly viewed culture can be seen as another type of risk for any organization. Viewed through this lens, culture can then be assessed, managed, monitored and improved as any other business risk. This has become even more important since the announcement in October 2021 by Deputy Attorney General Lisa Monaco, that the Department of Justice would assess corporate culture as a part of corporate compliance enforcement action. In this Part 4, we consider review how to monitor your culture risk  strategy for effectiveness with Michael Parker.

Michael Parker is a seasoned compliance professional with extensive experience in cultivating and sustaining a compliance culture within businesses. He asserts that there is no universal approach to establishing a compliance culture, emphasizing the necessity of providing options and guidance to employees, rather than merely imposing rules. Parker underscores the importance of continuous engagement and communication in managing compliance culture risks, and the crucial role of leadership in setting the tone for compliance and fostering an ethical culture throughout the organization. He also acknowledges the significance of incentives in promoting compliance, but stresses that the approach to incentivizing employees should be customized to individual circumstances and should include a clear understanding of the consequences of non-compliance.

Leadership plays a pivotal role in fostering a culture of compliance. Executives must lead by example and embody the organization’s mission and values. As Michael Parker emphasizes, it is not just about telling employees what to do but guiding them towards making the right decisions. Providing options and knowledge is essential, as people may unknowingly make decisions that go against policies or regulations due to a lack of information.

To ensure ongoing engagement, businesses should view compliance as an ongoing process rather than a one-time activity. This approach involves continuous listening and asking for feedback from employees. It is important to provide guidance rather than just guidelines, helping individuals understand the purpose behind compliance policies. By championing the organization’s values and mission, leadership can create a trickle-down effect, encouraging employees to align their actions with the desired culture.

Incentives also play a significant role in promoting compliance. Just as third parties have an incentive to complete certifications and engage in compliance efforts to do business with a company, employees have a vested interest in working for an organization that upholds ethical standards. By aligning incentives with compliance initiatives, businesses can motivate employees to actively participate in maintaining a compliance culture.

Technology can be a valuable tool in monitoring and educating employees about compliance. Micro-learning courses, compliance training videos, quizzes, and surveys can be used to deliver targeted and concise information. Short videos with quizzes can help raise awareness and educate employees on compliance topics. Surveys, when kept short and incentivized, can provide valuable insights into the effectiveness of compliance efforts and help measure the culture of compliance within the organization.

Tracking and storing compliance-related information is essential for transparency and visibility. Utilizing applications with dashboards can help businesses monitor engagement, track completion rates of training videos, and collect survey responses. This data can provide compliance officers with valuable information for ongoing monitoring and identifying areas that require additional training or education.

I believe the key is in viewing culture as a risk and applying risk management principles to assess and monitor compliance efforts. By treating culture as a risk, businesses can assess their compliance risk, identify gaps, and remediate as necessary. This approach allows for a systematic and proactive approach to managing compliance culture.

However, creating and maintaining a compliance culture is not without its challenges. Compliance fatigue can occur if communication and education efforts become overwhelming or burdensome. To combat this, shorter and more interactive methods, such as micro-learning and office hours, can be implemented. These shorter bursts of information align with today’s culture of brief and engaging content, making compliance education more accessible and less burdensome.

In conclusion, creating and maintaining a compliance culture in businesses requires a multifaceted approach. Leadership must champion the organization’s values and mission, while incentives and technology can motivate and educate employees. Viewing culture as a risk and applying risk management principles can help businesses assess and monitor their compliance efforts. By considering the impact on employees and adapting communication and education methods to align with today’s culture, businesses can foster a strong compliance culture that promotes ethical behavior and regulatory adherence.

Join us tomorrow where we explore the continuous improvement of corporate culture.

Tune into Michael Parker on the Diligent podcast series Unlocking Success: The Crucial Role of Culture in a Best Practices Compliance Program.

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Innovation in Compliance

Unlocking Success: The Crucial Role of Culture in Compliance: Part 4 – Michael Parker on Monitoring 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 4, we visit with Michael Parker to discuss a strategy to monitor your culture in the future.

Michael Parker is a seasoned compliance professional with extensive experience cultivating and sustaining a business compliance culture. He does not believe there is a one-stop,  universal approach to establishing a compliance culture, emphasizing the necessity of providing options and guidance to employees rather than merely imposing rules. Michael underscores the importance of continuous engagement and communication in managing compliance culture risks and the crucial role of leadership in setting the tone for compliance and fostering an ethical culture throughout the organization. He also acknowledges the significance of incentives in promoting compliance. Still, he stresses that incentivizing employees should be customized to individual circumstances and include a clear understanding of the consequences of non-compliance. Join Tom Fox and Michael Parker as they delve deeper into how to monitor your compliance program after you have created a culture management strategy in this episode of Unlocking Success: The Crucial Role of Culture in Compliance Best Practices podcast episode.

Key Highlights: 

  • Building a Compliance-Focused Leadership Culture
  • Leveraging Technology for Compliance Monitoring and Training
  • Driving Compliance Culture Through Executive Leadership

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 in our concluding episode, where we continuously consider how to improve culture in the future.

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Managing Culture Risk

Welcome to a special five-part blog series on building a stronger culture of compliance, sponsored by Diligent. In this series I will visit with Yvette Hollingsworth-Clark, Viktor Cuijak, Jessica Czeczuga; Michael Parker; and Alexander Cotoia. In this series, we will consider what is culture, how to assess culture, putting together a strategy to manage culture based upon this assessment, the monitoring of that strategy going forward and using information from your monitoring to engage in continuous improvement of your culture.

Many compliance professionals struggle with the ‘softness’ of culture. However, properly viewed culture can be seen as another type of risk for any organization. Viewed through this lens, culture can then be assessed, managed, monitored and improved as any other business risk. This has become even more important since the announcement in October 2021 by Deputy Attorney General Lisa Monaco, that the Department of Justice would assess corporate culture as a part of corporate compliance enforcement action. In this Part 3, we consider how to manage your culture risk through the crucial role of managers with assess your culture with Jessica Czeczuga.

Jessica Czeczuga is a seasoned professional with over two decades of experience in the training and development field, 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, being the most influential group within an organization, should be adequately trained to align with the desired culture and equipped with the necessary tools to effectively communicate and reinforce cultural values. Jessica also advocates for the collaboration between compliance professionals and HR to improve culture, leveraging their counseling skills and creating clear processes for reporting and addressing culture-related issues.

According to Czeczuga, managers are the most influential group in an organization when it comes to shaping company culture. They are the boots on the ground, constantly interacting with the employees that report to them. Their ability to talk and influence gives them a lot of power in driving the desired culture. Therefore, it is crucial for organizations to reach out to managers and get them on board with the desired culture, as they will naturally drive that message deeper into the organization.

She emphasized the importance of managers in shaping and reinforcing company culture was discussed. Managers play a significant role in driving the desired culture deeper into the organization, as they are in constant contact with employees and have the ability to support, promote, permit, or ignore certain behaviors and values.

To effectively manage culture, compliance professionals need to empower and train managers. Just like any other training program, a strong training program should be set up for managers, focusing not only on providing them with information about the desired culture but also on practical application. Role-playing and conversations with employees are key to driving behavior change and ensuring that managers are equipped to deliver the desired cultural messages.

The collaboration between HR and compliance departments is also important in reinforcing the importance of culture and driving a culture of reporting. HR, with its extensive touchpoints with employees, plays a crucial role in reinforcing compliance and culture messages. By partnering with HR, compliance professionals can ensure that the messages about culture are consistent and delivered from multiple angles, making them stronger and more impactful.

HR can also provide valuable insights and skills to the compliance function. HR has as many touchpoints with employees as any other corporate function, making it an ideal partner for compliance in reinforcing culture. HR can help compliance professionals in delivering messages about culture to different levels of employees and can provide guidance on how to address culture issues in conversations with employees.

The key takeaway is that managers have a crucial role in shaping and reinforcing company culture. They are the gatekeepers of culture and have the power to drive the desired culture deeper into the organization. To effectively manage culture, compliance professionals should focus on empowering and training managers, while also collaborating with HR to reinforce culture messages. Practical application, such as role-playing and conversations with employees, is key to driving behavior change and ensuring that managers are equipped to deliver the desired cultural messages.

In conclusion, the role of managers in shaping and reinforcing company culture cannot be underestimated. They have the ability to support, promote, permit, or ignore certain behaviors and values, making them the most influential group in an organization when it comes to culture. By empowering and training managers, and collaborating with HR, compliance professionals can effectively manage culture and drive the desired behaviors and values throughout the organization.

Join us tomorrow where we explore monitoring culture.

Tune into Jessica Czeczuga on the Diligent podcast series Unlocking Success: The Crucial Role of Culture in a Best Practices Compliance Program.

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Assessing Organizational Culture

Welcome to a special five-part blog series on building a stronger culture of compliance, sponsored by Diligent. In this series I will visit with Yvette Hollingsworth-Clark, Viktor Cuijak, Jessica Czeczuga; Michael Parker; and Alexander Cotoia. In this series, we will consider what is culture, how to assess culture, putting together a strategy to manage culture based upon this assessment, the monitoring of that strategy going forward and using information from your monitoring to engage in continuous improvement of your culture.

Many compliance professionals struggle with the ‘softness’ of culture. However, properly viewed culture can be seen as another type of risk for any organization. Viewed through this lens, culture can then be assessed, managed, monitored and improved as any other business risk. This has become even more important since the announcement in October 2021 by Deputy Attorney General Lisa Monaco, that the Department of Justice would assess corporate culture as a part of any corporate compliance enforcement action. In this Part 2, consider how to assess your culture with Viktor Cuijak.

Cuijak, a chartered accountant with a strong background in finance, audit, and risk consulting, 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, Cuijak firmly believes in the importance of 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. Cuijak 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. Crucial Role of Culture podcast.

Assessing and managing organizational culture as a risk factor is a crucial aspect of ensuring the success and sustainability of any organization. A compliance professional can begin by the using existing frameworks like COSO (Committee of Sponsoring Organizations of the Treadway Commission) for guidance in assessing and managing organizational culture. This framework provides principles and guidelines that help organizations understand the key factors that impact culture as a risk factor.

The tone at the top, policies, procedures, and feedback mechanisms were identified as key indicators of an organization’s culture. The tone at the top refers to the leadership’s actions and behaviors, which set the tone for the entire organization. Policies and procedures play a crucial role in shaping the desired culture, but it is not enough to simply have them in place. Actions, communications, and responses must align with the stated culture.

One of the key challenges is the nebulous and intangible nature of culture, which can make it difficult to assess and audit. However, Cuijak emphasized that culture can be thought of as just another risk that organizations need to manage. By asking the question, “What can go wrong?” organizations can identify potential risks and gaps in their culture and take steps to address them.

Standardized evaluation was also discussed as a valuable tool for assessing and benchmarking culture. It provides a common language and framework for managing risks associated with culture. By using evaluation tools, organizations can track their progress and identify areas for growth.

Cuijak also emphasized the importance of considering the impact of culture when making decisions. Culture is not just a checklist exercise, but rather a holistic approach that encompasses actions, communications, and responses. It is not enough to have policies and procedures in place; organizations must demonstrate their culture through their actions and communications.

While frameworks like COSO provide principles and guidance, they may not always provide the specific “how” in assessing and managing culture. This is where organizations need to tailor their approach and consider additional tools and techniques that align with their specific needs and goals.

In conclusion, assessing and managing organizational culture as a risk factor is a complex but essential task for organizations. By using existing frameworks, evaluating key indicators, and considering the impact of culture on decision-making, organizations can identify potential risks, address gaps, and create a culture that supports their overall success and sustainability.

Join us tomorrow where we explore creating a strategy to manage culture risk.

Tune into Viktor Cuijak on the Diligent podcast series Unlocking Success: The Crucial Role of Culture in a Best Practices Compliance Program.

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What is Corporate Culture?

Welcome to a special five-part blog series on building a stronger culture of compliance, sponsored by Diligent. In this series I will visit with Yvette Hollingsworth-Clark, Viktor Cuijak, Jessica Czeczuga; Michael Parker; and Alexander Cotoia. In this series, we will consider what is culture, how to assess culture, putting together a strategy to manage culture based upon this assessment, the monitoring of that strategy going forward and using information from your monitoring to engage in continuous improvement of your culture.

Many compliance professionals struggle with the ‘softness’ of culture. However, properly viewed culture can be seen as another type of risk for any organization. Viewed through this lens, culture can then be assessed, managed, monitored and improved as any other business risk. This has become even more important since the announcement in October 2021 by Deputy Attorney General Lisa Monaco, that the Department of Justice would assess corporate culture as a part of any corporate compliance enforcement action. In this Part 1, we ask what is culture with our special guest Yvette Hollingsworth-Clark.

Yvette currently holds the position of Chief Compliance Officer for State Street Corporation  and is on the Board of Directors at Diligent. With a robust background in risk management, Yvette has cultivated a deep understanding of the significance and measurement of corporate culture. 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 stressed the need for specific metrics to monitor and promote desired cultural values, such as integrity, and believes that culture can be measured through metrics such as the number of risk decisions overruled, challenged, or implemented correctly. She also highlighted the importance of considering stakeholders such as customers, clients, and third parties when assessing corporate culture.

Yvette emphasized that culture is not solely the responsibility of the compliance function but is owned by the C-suite and executed in various ways throughout the organization. CEOs have a significant role to play in driving corporate culture. They must lead by example, set expectations, and hold managers accountable for adhering to the desired cultural attributes.

One key aspect is the importance of tone from the top. Employees observe the behavior of their senior leaders and often mimic their actions. CEOs need to be conscious of the examples they set, both verbally and through their behavior. Fairness is also crucial in setting the culture of a company. Every decision made by senior leaders, regardless of their position, should demonstrate fairness and align with the desired culture.

The Board of Directors also plays a significant role in shaping and overseeing corporate culture. They need to understand how management defines culture and how ethical issues are managed within the organization. Yvette advises boards to think about the framework of culture more broadly, considering factors such as the company’s reputation to customers and other stakeholders, as well as the employee experience. It is essential to demonstrate how the organization is executing against the cultural attributes that are deemed positive for the company.

Assessing corporate culture is a complex task that requires a balance between art and science. While there are specific metrics that can be used to measure culture, such as risk decisions, policy violations, and disciplinary actions, it is important to anchor the assessment to the specific aspects of culture that are relevant to the organization. Yvette suggests using a suite of metrics that focus on risk excellence and positive indicators of culture, such as employee training, customer treatment, and incident handling.

One must always remember that assessing culture is not a one-size-fits-all approach. It requires organizations to be specific about what their data can answer and what it cannot. A culture assessment is still more of an art than a science, but it is crucial to have a clear understanding of the indicators that align with the organization’s desired culture.

In conclusion, corporate culture is of utmost importance in the financial services industry. It is not only the responsibility of the compliance function but is owned by the C-suite and executed throughout the organization. CEOs must lead by example and set expectations, while the board plays a significant role in shaping and overseeing culture. Assessing culture requires a balance between art and science, with organizations using specific metrics that align with their desired cultural attributes. By prioritizing and measuring culture, financial services organizations can create an environment that promotes ethical behavior, risk excellence, and positive outcomes for all stakeholders.

Join us tomorrow where we explore assessing organizational culture.

Tune into Yvette Hollingsworth-Clark on the Diligent-sponsored podcast series Unlocking Success: The Crucial Role of Culture in a Best Practices Compliance Program.

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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.

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Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 5 – The Role of the Board of Directors

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series, Tom Fox visits with Kunal Agrawal, Director of Customer Success at Diligent; Kevin McCoy, Customer Success Manager at Diligent; Jessica Czeczuga, Director, Compliance and Ethics at Diligent; Andrew Rincón, Client Director at Diligent; and David Greenberg, former CEO and Special Advisor at LRN and Director at International Seaways. Over this series, we will consider the importance of ongoing communications, the value of targeted training, training third parties, and the role of the Board of Directors. In this Part 5, we discuss the role of the Board of Directors in a compliance program.

Navigating the complex corporate governance and compliance world is challenging but essential for board members. Ensuring the company operates within legal, ethical, and social confines is vital to effective board governance. Boards that fail to achieve high compliance standards can suffer reputational damage, financial penalties, and even legal consequences. It is, therefore, critical for board members to engage with the importance of their oversight role and invest in the necessary education and best practices to ensure they effectively fulfill this responsibility. Here are the key steps:

1. Understand the Board’s oversight responsibilities.

2. Establish strong communication with management.

3. Ensure compliance programs are integrated into the company’s DNA.

Understand the Board’s oversight responsibilities. Board members ensure a company’s ethical standards, compliance, and performance.  Understanding a Board’s oversight responsibilities is paramount to effectively governing and managing the organization. Every Board has a fiduciary duty to protect the stakeholders’ interests and ensure the company’s compliance with laws, regulations, and policies. To meet this legal requirement, Board members should know current best practices, emerging trends, and the legislative and regulatory landscape and be prepared to ask tough questions, follow up, and support management in executing the company’s plans.

Greenberg discussed the importance of a healthy relationship between the Board and the Chief Compliance Officer (CCO). Greenberg emphasized that the role of the Board is one of oversight rather than execution. This entails the need for ongoing dialogue and frequent reporting by the CCO to ensure the Board is informed of the company’s activities, risks, and potential blind spots. Greenberg also recommends that oversight committees take a hands-on deep-dive approach to identify and address potential issues, ensuring the compliance program is ingrained within the company culture and business strategy. Companies must find the appropriate committee with the right people and relevant interests to oversee compliance and advocate for common membership across committees to ensure strategic integration and prevent fragmentation. For Board members, understanding their oversight responsibilities is essential to foster robust corporate governance, risk management, and compliance.

Establish strong communication with management. Establishing strong communication with management is critical for an effective board oversight process. This key step involves board members working closely with senior management and the CCO to ensure that all compliance-related matters are addressed promptly and accurately. By fostering a healthy rapport with management, Board members can actively engage in oversight and be more proactive in remedying compliance-related issues. This collaborative relationship between the Board and management is essential for companies to maintain compliance with laws and policies, ultimately safeguarding the organization’s reputation and performance. Greenberg emphasizes the importance of strong communication between the compliance officers and the Board.

CCOs should develop close relationships with board members, much like senior managers. Greenberg noted this could involve CCOs meeting with board members outside of scheduled meetings to discuss concerns or potential issues. By doing so, a CCO can build trust and foster open communication, allowing board members to comprehensively understand the company’s compliance efforts. Greenberg also emphasized the value of having the right committee and membership, which includes individuals with the background, interests, and time necessary to effectively carry out their oversight duties. This key step is vital for board members because open and direct communication with management enables the Board to strategically address compliance matters, resulting in improved oversight and risk mitigation. Moreover, when board members have a strong rapport with management, they can proactively identify and address any issues before escalating.

Ensure compliance programs are integrated into the company’s DNA. In successfully executing their compliance oversight duties, Boards must ensure that their compliance programs are integrated into the company’s DNA, or as the DOJ says, it’s all about culture. Such integration fosters a strong culture of compliance, which is crucial in minimizing misconduct, reducing legal risks, and protecting the organization’s reputation. By incorporating compliance as a core element within the company’s strategic planning, daily operations, and employee training, boards can better manage risks and ensure adherence to relevant laws, regulations, and policies. Further, a fully integrated compliance program will enhance overall corporate performance, customer trust, and employee engagement.

For a Board to effectively exercise its oversight duties, compliance programs should be tailored to the organization’s business strategy, culture, and resources. The relationship between the Board, senior management, and the CCO can facilitate effective communication and better coordination in addressing critical ethics and compliance matters. The Board must ask tough questions and dive deep into possible issues to ensure transparency and accountability. By embedding compliance within the organization’s structural and cultural fabric, boards can create a robust environment that discourages misconduct while promoting transparency, accountability, and ethical behavior. This safeguards the company’s reputation, financial performance, and regulatory compliance. Ensuring seamless integration of compliance programs is a vital obligation for the boards, enabling them to effectively fulfill their oversight responsibilities and protect the organization’s long-term interests.

For Board members, the importance of robust oversight and compliance cannot be overstated, especially in a world where regulatory scrutiny grows more intense by the day. By following these steps, you can hone your understanding of the Board’s oversight responsibilities, establish solid communication channels with management, and embed a culture of compliance across your organization. Equipping yourself with these essential practices empowers you to tackle complex compliance challenges head-on and steer your organization toward success. As you continue sharpening your oversight skills, you will foster a resilient compliance framework that safeguards your organization and its stakeholders.

For more information, go to Diligent.com.

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Innovation in Compliance

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 5 – The Role of the Board

Welcome to a special 5 part podcast series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series, I will visit with Kunal Agrawal, Director of Customer Success at Diligent; Kevin McCoy, Customer Success Manager at Diligent; Jessica Czeczuga, Director, Compliance and Ethics at Diligent; Andrew Rincón, Client Director at Diligent; and David Greenberg, former CEO and Special Advisor at LRN and Director at International Seaways. Over this series, we will consider the importance of ongoing communications, the value of targeted training, training third parties, and the role of the Board of Directors. In this concluding Part 5, we consider the role of the Board of Directors in a compliance program with David Greenberg.

In this episode, Greenberg discusses the board’s legal obligations, emphasizing their duty to exercise reasonable oversight over potential misconduct and failures of compliance with law and policy. The podcast also delves into the importance of integrating compliance programs into a company’s overall strategy and developing strong relationships with senior management, such as the chief legal officer or chief compliance officer. Listeners will learn the importance of finding the right committee to oversee compliance obligations and utilizing outside experts for insight and guidance. This conversation is essential for board members and executives who want to ensure accountability, initiate change, and drive organizational success. Don’t miss out on this informative and engaging episode of “The Role of the Board” episode.

Key Highlights:

  • Legal obligations and oversight for corporate boards
  • Importance of integrating compliance into the company culture
  • Board Oversight and Relationship Building with CCO
  • The Significance of Outside Perspectives for Boards

Notable Quotes:

“There is a strong obligation on boards to exercise reasonable oversight over all potential misconduct and failures of compliance law and policy should a reasonable board has known and taken steps…should that body have known and should it have done more than it did.”

“Boards principally should be asking tough questions and following up on those questions.”

“Anything that is not integrated into the real levers and machinery of the business will not be successful.”

“That chief compliance officer who knows the head of the audit committee or compliance committee or governance committee is much more able and comfortable picking up the phone and saying to the chair, Houston, we’ve got a problem.”

For more information go to Diligent.com

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Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 4-A Training Program for 3rd Parties

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer Success at Diligent; Kevin McCoy, Customer Success Manager at Diligent; Jessica Czeczuga, a Principal Instructional Designer; Andrew Rincon, Global Accounts Management Advisor at Diligent; and David Greenberg, former CEO and Special Advisor at LRN and Director at International Seaways. Over this series, we will consider the importance of ongoing communications, the value of targeted training, training third-parties, and the role of the Board of Directors. In this Part 4, we discuss how to put together a training program for third parties with Andrew Rincon.

In today’s global business landscape, third-party compliance training are more crucial than ever. Ensuring that your organization’s distributors, vendors, and other third-party affiliates adhere to necessary regulations can minimize legal and financial risks, protect your company’s reputation, and foster a culture of ethical business practices. As compliance professionals responsible for training these third parties, it’s essential to stay informed about cutting-edge strategies and techniques for effective risk management. This blog will explore practical steps that can be implemented to improve your third-party compliance training and due diligence processes, allowing you to uphold your organization’s regulatory standards and contribute positively to the industry. Here are the steps to get Improved third-party compliance training and due diligence processes.:

1. Assess third-party risk during onboarding.

2. Utilize micro training videos for efficiency.

3. Customize training materials for specific regions.

Assess third-party risk during onboarding. Due Diligence on and assessing third-party risk is not a ‘one size fits all’ process. This critical step allows organizations to identify high-risk distributors, vendors, and other third parties that may pose potential threats to the business in terms of bribery, corruption, and other regulatory violations. By conducting a thorough risk assessment, organizations can effectively mitigate these risks and ensure that they are partnering with ethical and responsible businesses, ultimately fostering a strong culture of compliance throughout their sales or supply chain ecosystem. Moreover, such an approach is critical throughout the lifecycle of the relationship. Rincon emphasized the importance of proactive ongoing due diligence measures, such as automated screenings and monitoring, sending out attestations, and conducting regular training courses.

Effectively educating, resellers, agents distributors and other third-parties on compliance policies and expectations is critical and cannot be overstated. Providing proactive training not only helps in preventing compliance violations but also demonstrates to regulators your organization’s commitment to maintaining high ethical standards. This, in turn, can mitigate penalties in case of inadvertent violations and foster a trust-based relationship with regulatory authorities. By adopting these practices and leveraging technology to automate certain processes, organizations can ensure that they are partnering with ethical third parties, minimize their exposure to regulatory risks, and foster a strong culture of compliance across their entire network. By doing so, they not only protect their businesses from potential harm but also contribute to a more transparent and ethical global marketplace.

Utilize micro training videos for efficiency. In the field of compliance, training third parties remains a critical aspect of managing and mitigating risks associated with regulatory and legal frameworks such as the Foreign Corrupt Practices Act (FCPA). With the increasing need for efficient and effective compliance processes, it becomes essential for compliance professionals to employ innovative strategies to achieve their objectives while minimizing disruptions to business operations. By leveraging this method, companies can ensure that their distributers and internal client gatekeepers receive consistent and easily digestible information, enhancing their understanding of compliance policies and expectations.

Rincon said that by breaking down complex topics into easily understandable portions, micro training videos enable organizations to communicate the essential aspects of their compliance policies and expectations in a concise and engaging manner. Through the ability to cater to different audiences, these training resources contribute to a more comprehensive approach towards addressing third-party risk. The adoption of micro training videos as a tool for third-party compliance education serves an essential purpose for compliance professionals. By incorporating this method, companies can enhance their third-party risk management processes and ensure that their partners are aware of the applicable legal and regulatory frameworks. This leads to improved adherence to compliance policies, reduced likelihood of violations, and overall risk mitigation.

Customize training materials for specific regions. Effective third-party compliance training often involve the customization of training materials for specific regions. This ensures that the training is relevant, relatable, and impactful for third parties, taking into account regional differences, languages, and sensibilities. Customizing training materials also fosters a deeper and more nuanced understanding of the compliance policies and expectations towards each party, thereby mitigating the risks associated with inadequate understanding or implementation of compliance standards. Furthermore, cultural sensitivities and regional variations can be taken into account when designing training, ensuring a more engaging and effective learning experience for the target audience.

Rincon micro-training video shorts can be easily customized for different regions and translated into multiple languages. With such versatile tools, compliance professionals can promote clear and concise messaging to their third-party partners, thus reinforcing the importance of compliance policies and due diligence throughout the duration of the business relationship. Customizing compliance training materials for specific regions not only makes the training more effective, engaging and relevant but also supports robust risk management and streamlined third-party due diligence processes.

For compliance professionals dedicated to training third parties, the effectiveness of your compliance and due diligence processes plays a significant role in safeguarding your organization from potential risks. The steps discussed, including customizing training materials for specific regions, agents, reseller, distributors and other business parnters on compliance policies and using technology to track irregularities, can greatly enhance your efforts to ensure that your third parties meet and maintain compliance expectations. With diligent application of the guidance provided, you can foster a well-informed and compliant network of third parties, ultimately ensuring your organization’s ongoing success.

For more information go to http://diligent.com/compliancetraining.

Join us tomorrow where we review the role of the Board of Directors in a compliance regime.