Tag: Diligent

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Renee Murphy on Risks and Consequences of Board Level Conflicts of Interest

I recently had the opportunity to visit with folks from Diligent. We look down the road at key issues in 2024 in a podcast series sponsored by Diligent entitled Compliance Professionals Adapting to Change: Industries, Regulations, and Beyond. I could chat with Nicholas Latham, Renee Murphy, Jessica Czeczuga, Yee Chow, and Alexander Cotoia. Over this series, we discussed compliance communications in regulated industries, managing conflicts of interest at the Board level, the Board’s role in compliance training and communications, navigating the current ESG landscape, and professional growth and mentorship in compliance. In this Post 2, we discuss the conflicts of interest at the Board of Directors and the Board’s role at the ESG level with Renee Murphy.

Conflicts of interest at the board level can have serious implications for companies, requiring careful management and proactive measures to ensure ethical functioning. Board-level conflicts of interest can arise when board members sit on multiple boards or engage in self-dealing. These conflicts can lead to questions of fairness and potential harm to the company. For example, a CEO whose time is divided among multiple companies may not be able to provide fair attention to each organization, creating a conflict of interest for shareholders. Additionally, self-dealing at the board level, such as funneling company funds to entities owned by board members, can harm the company’s financial health.

To mitigate these conflicts, board members should establish clear boundaries and implement board management software for transparency and accountability. This software enables effective communication and decision-making, allowing boards to address conflicts promptly and ensure ethical operations. Compliance and risk management officials play a vital role in board governance by providing the board with an understanding of legal and regulatory risks and preventing conflicts of interest. These officials enable efficient risk management and compliance processes by utilizing governance software.

The implementation of ESG practices is another crucial aspect of board governance. ESG considers environmental, social, and governance factors in business operations. Companies are advised to select a framework and start disclosing their ESG information. Failure to do so can hinder access to capital and affect long-term risk management. While ESG practices are not currently mandated by the SEC, they are increasingly demanded by banks, customers, and third parties. Therefore, companies have no choice but to disclose their ESG practices to meet stakeholder expectations.

Balancing board-level conflicts of interest and ESG practices involves tradeoffs and challenges. On one hand, addressing conflicts of interest requires strict oversight and accountability to ensure fair decision-making. On the other hand, implementing ESG practices requires companies to consider their environmental and social impact, which may involve additional costs and changes to existing operations. Finding the right balance between these factors is crucial for organizations to maintain ethical operations while meeting stakeholder expectations.

The importance of considering the impact on decision-making cannot be overstated. Conflicts of interest and the lack of ESG practices can lead to financial losses, reputational damage, and legal consequences. By proactively managing conflicts and implementing ESG practices, companies can enhance their long-term sustainability and mitigate risks. Compliance and risk management officials and board members play a pivotal role in ensuring that ethical considerations are prioritized in decision-making processes.

Managing board-level conflicts of interest and implementing ESG practices are critical aspects of board governance. Companies can enhance transparency, accountability, and ethical functioning by establishing clear boundaries, utilizing board management software, and disclosing ESG information. Balancing these factors involves tradeoffs and challenges, but the impact on decision-making and the long-term success of organizations cannot be ignored. With the guidance of compliance and risk management officials, boards can navigate these complexities and ensure ethical operations for the benefit of all stakeholders.

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 as we consider the role of the Board of Directors in compliance training and communications.

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Innovation in Compliance

Compliance Professionals Adapting to Change: Industries, Regulations, and Beyond: Part 1 – Nicholas Latham on Compliant Communications

Welcome to a special series sponsored by Diligent, where we look down the road at key issues in 2024 and beyond. In this series, I will visit with Nicholas Latham, Renee Murphy, Jessica Czeczuga, Yee Chow, and Alexander Cotoia. Over this series, we will consider compliant communications in regulated industries, managing conflicts of interest at the Board level, the Board’s role in compliance training and communications, navigating the current ESG landscape, and professional growth and mentorship in compliance. In this Part 1, we consider compliant communications in regulated industries with Nicholas Latham.

Nicholas Latham is an accounting professional with a strong accounting and risk management background, currently serving as a Client Partner at Diligent Corporation. His perspective on accounting and risk assessment is shaped by his extensive experience in the financial industry, particularly in the collections department of a US bank. Nicholas believes that organizations must implement and adapt frameworks such as COSO and ISO 31,000 to manage and mitigate risks effectively. He also emphasizes the need for a holistic view of risk and control across the entire organization rather than siloed departments, and he believes these frameworks can help provide a comprehensive understanding of the organization’s risk landscape. Join Tom Fox and Nicholas Latham on this episode of the Diligent Podcast as they delve deeper into Latham’s expertise in governmental accounting and risk assessment.

Key Highlights:

  • Risk and Control Expertise in Professional Background
  • Assessing and Mitigating Risk in Organizations
  • Holistic View of Organizational Operations and Risk

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 will consider managing conflicts of interest at the Board of Directors.

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The Continuous Improvement of Corporate Culture

Welcome to a special five-part blog series on building a stronger culture of compliance, sponsored by Diligent. Over this series I have visited with Yvette Hollingsworth-Clark, Viktor Cuijak, Jessica Czeczuga; Michael Parker; and today it is Alexander Cotoia. In this series, we considered 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. We conclude on how to use this 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 concluding Part 5, we consider how to continuously improve your compliance program with Alexander Cotoia, from the Volkov Law Group.

Alexander Cotoia, a regulatory compliance manager at the Volkov Law Group, has a rich background in commercial litigation and has spent a significant part of his career as a paralegal before transitioning to an in-house role at Virgin Galactic. Cotoia 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. Cotoia suggests that organizations should reinforce their values and highlight the economic benefits of compliance to gain buy-in and engagement from employees, while also emphasizing the need for continuous improvement, conducting root cause analysis, and involving various stakeholders to address cultural issues effectively.

At its core, compliance culture is about promoting and encouraging behavior that aligns with ethical and legal standards. It goes beyond simply following rules and regulations; it involves fostering an environment where employees understand the importance of compliance and are committed to upholding it. As Cotoia emphasized, creating a culture of compliance makes good business sense in today’s era, where consumers are more informed than ever before and a new generation of employees are demanding that organizations align with their values.

One key aspect highlighted in the podcast episode is the role of leadership, particularly the CEO, in driving and reinforcing a culture of compliance. Cotoia stressed the importance of CEOs being actively involved in the compliance process, emphasizing the organization’s values, and demonstrating how compliance contributes to the overall success of the organization. By doing so, CEOs can set the tone at the top and inspire employees to embrace compliance as an integral part of their work.

To establish and maintain a culture of compliance, organizations need to employ various tools and strategies. Cotoia discussed the importance of conducting root cause analysis, which involves identifying the underlying causes of non-compliance or ethical lapses. This analysis can be facilitated through anonymous surveys that measure employees’ perception of compliance within the organization and the extent to which compliance concerns are integrated into their daily work. By understanding the root causes, organizations can implement targeted remedial measures to address the identified issues.

Collaboration among stakeholders is also crucial in promoting a culture of compliance. Cotoia emphasized the need for involvement from various departments, such as the financial team, legal, and compliance officers, depending on the specific compliance challenges faced by the organization. By working together, these stakeholders can collectively solve problems and ensure that compliance is embedded throughout the organization.

Monitoring the effectiveness of remedial measures is another critical aspect of compliance culture. Organizations should regularly assess whether the implemented measures are achieving the desired outcomes. This can be done through continuous improvement efforts, such as periodic pulse checks and assessments of employee understanding and engagement with compliance initiatives. If the results indicate that the remedial efforts are not effective, organizations should be willing to revisit the root cause analysis and adjust their approach accordingly.

We also discussed the importance of ongoing communication and collaboration for continuous improvement and alignment with compliance standards. Organizations should foster an environment where employees feel comfortable reporting compliance concerns and where open dialogue is encouraged. This not only helps identify potential issues but also demonstrates the organization’s commitment to addressing them.

In conclusion, the importance of compliance culture in organizations cannot be overstated. It not only minimizes ethical and legal risks but also contributes to the overall success and reputation of the organization. By involving leadership, conducting root cause analysis, collaborating with stakeholders, monitoring effectiveness, and fostering ongoing communication, organizations can create and maintain a culture of compliance that aligns with best practices and meets the expectations of employees and consumers alike. As Alexander Cotoia aptly stated, “Creating a culture of compliance just makes good business sense.”

Tune into Alexander Cotoia 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 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.