Tag: employee engagement

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The 2024 ECCP – Using Data Analytics to Determine Employee Engagement, Trust, and Corporate Culture

In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke about the CWA and reviewed its early developments. (A copy of her remarks can be found here.) There was also updated information on the DOJ approach to whistleblowers and anti-retaliation found in the 2024 Update to the Evaluation of Corporate Compliance Programs (2024 ECCP). She addressed the growing importance of using data analytics to evaluate key aspects of a company’s corporate culture, particularly employee engagement, trust, and overall corporate ethics.

Assessing corporate culture is essential for compliance professionals. Culture is a powerful determinant of whether employees will adhere to company policies, report misconduct, and act ethically. The DOJ has made it clear through the 2024 ECCP that an organization’s culture of compliance is as critical as the controls themselves. Compliance programs must go beyond preventing misconduct and cultivate a culture where ethics and transparency are prioritized.

Employee engagement and trust are at the heart of this culture. Engaged employees are more likely to comply with rules and report issues. However, if there is a lack of trust—whether in the company’s leadership, policies, or reporting mechanisms—the risk of ethical lapses and misconduct increases. Data analytics can offer compliance professionals actionable insights into these hard-to-measure elements of corporate culture.

Leveraging Data Analytics for Cultural Insights

Traditionally, companies have relied on surveys, focus groups, and audits to assess employee engagement and trust. Despite their value, these methods frequently have limitations due to low response rates, biases, and a point-in-time perspective. On the other hand, data analytics offers ongoing, real-time insights across various indicators. Let’s explore how data analytics can help evaluate employee engagement, trust, and corporate culture:

Employee Engagement Data

Employee engagement can be a key indicator of whether a compliance program is likely to succeed. High levels of engagement suggest that employees are motivated, aligned with corporate values, and likely to act in the company’s best interest.

Metrics to Consider

  • Employee Feedback Platforms. Tracking data from feedback platforms (such as pulse surveys or anonymous feedback tools) can provide insights into employee sentiment about their work environment and leadership.
  • Participation in Training Programs. Data on employee participation in compliance training—especially voluntary programs—can offer insights into employees’ engagement with the company’s compliance initiatives.
  • Use of Corporate Tools. Monitoring internal systems such as compliance hotlines, whistleblower portals, and internal messaging boards can help assess whether employees feel empowered to engage with compliance resources.

By monitoring engagement trends over time, compliance officers can detect shifts in employee engagement and intervene if levels drop. For instance, increasing non-compliance with mandatory training could be a red flag for broader cultural issues.

Trust in Leadership and Compliance Programs

Trust is a critical component of a successful corporate compliance culture. If employees do not trust leadership or the compliance function, they are less likely to report misconduct and more likely to turn a blind eye to ethical violations.

Metrics to Consider

  • Whistleblower Reporting. Data on the number of whistleblower reports can be telling. A lack of reports may not necessarily indicate a lack of issues—it could signal a fear of retaliation or distrust in the reporting process.
  • Retention Rates in High-Risk Areas. Monitoring employee turnover in areas that are considered high-risk (e.g., finance, procurement, or overseas offices) can help determine whether ethical concerns are driving departures.
  • Survey Data on Trust Levels. Regular employee surveys on perceptions of leadership and the compliance program can offer a pulse on trust. The key is to go beyond traditional engagement surveys and ask questions about ethical concerns and trust in compliance leadership.

Combining survey data with data from whistleblower systems and employee retention analytics can offer a more nuanced view of whether employees trust leadership. A low reporting rate and high turnover in high-risk areas may indicate deeper cultural problems requiring intervention.

Monitoring Employee Behavior and Risk Indicators

One of the most significant ways data analytics can support compliance efforts is by detecting behavioral patterns that may indicate a lapse in corporate culture or potential compliance risks.

Metrics to Consider

  • Expense and Travel Data. Analyzing expense reports and travel data patterns can reveal inconsistencies or potential misconduct, such as fraudulent claims or unauthorized spending.
  • Email and Communication Analysis. Some companies use natural language processing (NLP) tools to analyze internal communications for warning signs of ethical issues. This can include detecting language that suggests rule-breaking, covering up misconduct, or expressing discontent with corporate policies.
  • Business Unit Performance vs. Compliance Reporting. Comparing performance data across business units with the frequency of compliance-related issues can provide insights into whether high-performing units are cutting corners to achieve their results.

Behavioral analytics can help compliance professionals detect patterns before they escalate into larger issues. For example, if a particular business unit shows exceptional financial performance but is under-reporting compliance concerns, this could signal a risky culture of non-compliance.

Driving a Data-Driven Culture of Compliance

Implementing data analytics in your compliance program requires the right technology, processes, and, most importantly, corporate buy-in. As the DOJ highlighted in its recent updates to the 2024 ECCP, compliance personnel must have adequate access to relevant data sources and the resources to interpret and act on that data. Companies should invest in the same level of technology for their compliance functions as they do for their business operations.

Some of the keys every compliance program should consider to help implement a data-driven culture of compliance include the following strategies:.

  • Build Cross-Functional Partnerships. Compliance teams should collaborate with human resources, IT, and business operations to gain access to the data they need. A cross-functional approach ensures compliance data is integrated into the company’s broader performance metrics.
  • Foster Transparency in Data Use. Be clear with employees about how their data will be used, particularly in sensitive areas such as monitoring communication. Emphasizing the ethical use of data can help build trust.
  • Regularly Reassess Your Metrics. As with any compliance program, the metrics used to evaluate corporate culture should evolve. New risks, technologies, and business challenges should inform your data strategy.

Strengthening Compliance through Analytics

The DOJ made clear in the Argentieri speech and the 2024 Update to the Evaluation of Corporate Compliance Programs that a data-driven approach to understanding employee engagement, trust, and corporate culture is essential for compliance success. Data analytics offers compliance professionals powerful tools to assess whether employees are following the rules and truly engaged in creating an ethical and compliant corporate environment.

As we look toward the future, companies prioritizing data analytics in their compliance programs will be better equipped to prevent misconduct, identify cultural risks, and foster a workplace that values ethics and transparency. For compliance officers, the time is now to embrace data analytics and use it to reinforce the foundation of a strong corporate compliance program.

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Compliance Tip of the Day

Compliance Tip of the Day: A Listening Tour for Employee Engagement

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we explore how and why a listening tour can be a powerful tool to engage employees.

 

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: To Improve Culture, Engage More

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we explain why perhaps the key factor in corporate culture is employee engagement.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Blog

Culture Week: Part 4 – Employee Engagement to Improve Culture

Suppose there is one thing I have learned from working with Carsten Tams, an ethical business architect and founder and chief executive officer (CEO) of Emagence LLC. In that case, employee engagement is one of the very top keys to a successful compliance program. Tams and I explored this topic in the popular Design Thinking in Compliance podcast series. It also appears that engagement can lead to excellent business resiliency based on an article in the MIT Sloan Management Review, entitled The Top 10 Findings on Resilience and Engagement, by Marcus Buckingham. Covid 19 and the Russian invasion of Ukraine changed business forever, making business resiliency a key trait for any business, corporate function, and especially a Chief Compliance Officer (CCO) or compliance professional. That last arena is where engagement is so critical.

The author defined resilience as “the capacity of an individual to withstand, bounce back from, and work through challenging circumstances or events.” However, it is also a “reactive capacity, describing how people will respond when challenges arise.” Conversely, engagement was seen as a proactive state of mind. The authors defined the criteria by making such inquiries “as how clear their expectations were, whether they got to use their strengths every day, whether they felt they would be recognized for doing excellent work, and whether someone at work was encouraging them to grow.” Yet, the most exciting part is the dichotomy between reactive and proactive. It is a bit like the difference in prevention and detection in a compliance program. The former is preferred to stop illegal or unethical conduct, so you do not have to detect it.

Not surprisingly, trust is the number one factor in both engagement and resilience. Astoundingly, the author found that “employees who said they completely trust their team leader were 14 times more likely to be fully engaged.” Moreover, those employees who completely trusted their colleagues, team leader, and senior leaders “were 42 times more likely to be highly resilient.” The reason should seem obvious as it is undoubtedly “easier to engage in our best work when we don’t have to expend mental resources looking over our shoulders or protecting ourselves against dysfunctional workplace practices that erode trust, like bullying or micromanaging. When it comes to building engagement and resilience, trust is everything.” [emphasis added throughout]

Teamwork is also a key factor. Although this is not something I have experienced over the past 12 years of working alone, the author found, “Those who said they are on a team were 2.6 times more likely to be fully engaged and 2.7 times more likely to be highly resilient than those who didn’t identify as team members. For millennia, humans have experienced psychological well-being only when they feel connected to and supported by a small group of people around them.” When the pandemic hit, working from home (WFH) was not new to me as I had been doing it since 2010, but even in the WFH or Hybrid Work era, most employees need to feel like they are part of a team.

However, being or even feeling like you are a part of a team is a state of mind, not a state of place. I always feel engaged with my blog posts, article readers, podcast listeners, and the greater compliance community. Based on that experience, I agree with the author’s statement that “engagement and resilience are about who you work with, not where you’re working.” Moreover, he noted, “virtual workers are both more engaged and resilient than those physically in an office or shared workspace … In 2020, well into the pandemic, 20% of virtual workers were fully engaged, and 18% were highly resilient—a stark contrast to the 11% of fully engaged and 9% of highly resilient office-based workers during the same period. How the work is done and with whom people work are important, but organizations can stop worrying about whether virtual work is detrimental to teamwork.” Even more than teamwork, it is about having relationships with your co-workers. The author stated, “Relationships boost resilience. Women are not more resilient than men, or vice versa … This data strongly suggests that it is much harder to summon and sustain one’s resilience when going through life alone.”

I can certainly attest that the unknown is more terrifying than change. The author found that employees “who reported five or more changes at work were 13 times more likely to be highly resilient. This suggests that we humans fear the unknown more than we fear change. Company leaders shouldn’t rush employees back to normalcy when so much of the danger inherent in this current ‘normalcy’ remains unknown and unknowable. Instead, leaders should tell their teams specifically what changes they are making to their work and why to increase their overall level of resilience.”

These findings suggest that every CCO and compliance professional must work to lessen or dissolve the disconnect between senior leadership and front-line workers. Your front-line business folks will make or break your compliance program. Getting your senior management more engaged will create and establish the trust that your employees will need to show resilience in the face of the following major business location, whether a pandemic or military invasion. Giving employees needed clarity and specificity from leaders, not sugarcoated enthusiasm, will help drive this trust. The author ended this concept by stating, “Leaders need to see their employees not as ‘labor’ but as the messy, complex, emotional beings they are—dealing with real-world human challenges, just like they are. The more leaders can infuse these findings in their organizations’ policies and practices, the more likely we will all be to flourish, both during these difficult times and beyond.”

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Blog

Improving Corporate Culture Through Podcasting

Podcasting has become increasingly popular over the past decade, providing businesses with a new and innovative way to communicate with their audience. In simple terms, podcasting is the creation and distribution of audio content that can be downloaded and listened to at a later time. Podcasts are typically distributed through various platforms, such as iTunes or Spotify, and can be downloaded and listened to via a smartphone or computer.

One of the biggest benefits of podcasting is that it allows businesses to connect with their audience on a more personal level. Unlike traditional forms of advertising, which often come across as impersonal and sales-driven, podcasts enable businesses to build a loyal following by offering valuable and engaging content. This can include interviews with industry experts, behind-the-scenes glimpses of the business, and informative discussions on relevant topics.

Now take these same concepts of audience engagement and apply them internally to an organization. What do you potentially have? A mechanism to engage your employees, to engender trust and improve your overall corporate culture. Do you think this is a crazy way to improve culture? Think again about all the advantages podcasting has in place already.

A major US consumer product company started a podcast and had corporate executives on it. Who were the biggest fans of the podcast? It turned out it was the company employees, many of whom had never met their corporate executives. This allowed the executives to be humanized in a way no number of town hall meetings or other similar corporate events could ever achieve.

One of the biggest advantages of podcasting is that it is a relatively inexpensive way to reach a large audience. Unlike traditional forms of internal advertising for a compliance function, which can be expensive and difficult to track, podcasting allows businesses to reach a global audience with minimal investment. This can be particularly beneficial for corporate compliance programs which want to engage their customer base (IE., employees) in a new way that are looking to build their brand and expand their reach.

Podcasting is a powerful tool that businesses can use to connect with their audience on a more personal level. By investing in the right equipment and software, corporations can create engaging and informative audio content that will help build their ethical brand (culture) and drive employee engagement. If you want a new and different way to talk to your employees, why not try podcasting.

In today’s world, podcasting has become an essential tool for businesses to reach out to their target audience. With the rise of social media and the internet, it is crucial for businesses to utilize all available platforms to promote their products and services. Podcasting is one such platform that has gained immense popularity in recent years.

Want some other options? How about a fully produced branded podcast series for your internal compliance function. It could be two 25–30-minute episodes per month, with the guest selected by your compliance team. This format allows your corporate compliance function to tell the story of its greatest asset, its people, through interviews. Cannot get out of the country to travel? Still working remotely? Your branded podcasts give you a way to reach your employees as we continue to struggle through the Covid-19 variants. You can use the branded podcast to tell the story of compliance successes in your organization; you can include other departments to share their successes too. As with the podcast storytelling series, it would be done in a collaborative manner working with your comms team.

Want to make some short and snappy compliance communications? How about ‘Compliance News of the Day’? Have a daily curated news show of 3-4 compliance stories with a short summary of the series and how it relates to a compliance perspective to your organization. Make it fun so your employees want to check in daily. When the DOJ comes knocking and asks how often you send out compliance communications, you can point to your Compliance News of the Day as a great starting point.

As a compliance practitioner, you should strive to bring more storytelling into your compliance messaging, training and communications. If you put the employee in the shoes of the person they’re watching, they will remember it, because they will see how it applies to their lives. Such training and communication experiences will last much longer than if you drone over a written policy or show a PowerPoint. This is “expanding your classroom.” Ronnie Feldman calls this bringing memorable storytelling to your compliance communications and training.

One of the significant benefits of podcasting for a corporate compliance function is that it helps create a personal connection with the audience. Unlike other forms of internal communications, podcasting allows businesses to speak directly to their employees in a conversational and engaging manner. This helps to build trust and credibility with the audience, which can lead to increased sales and customer loyalty.

Podcasting also provides businesses with an opportunity to showcase their expertise and knowledge. By creating valuable and informative content, corporate compliance programs can establish themselves as leaders in their company to help employees facilitate issues and not be Dr. No From the Land of No. This can help to engage employees.

Another significant advantage of podcasting is that it is a highly shareable medium. Listeners can easily share podcast episodes on social media platforms, which can help to increase the reach of any corporate compliance function. This can help to attract new listeners from your employee base, as well as increase engagement with existing ones.

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

Finally, if you need any help starting a podcast, ping me and I can help you get started or provide you a turnkey podcast solution.

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Daily Compliance News

Daily Compliance News: June 14, 2023 – The Digital Nomad Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen 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.

  • Why we go into the office now. (Bloomberg)
  • JPMorgan settles with Epstein victims for $290M. (Reuters)
  • Corruption and wildfires. (Eurasianet)
  • The digital nomad goes corporate. (FT)
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Sunday Book Review

Sunday Book Review: May 21, 2023 – The Employee Engagement Edition

In the Sunday Book Review, I consider books that interest the compliance professional, the business executive, or anyone curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest me. In today’s edition of the Sunday Book Review, we look at books on employee engagement:

  • The Truth About Employee Engagement: A Fable About Addressing the Three Root Causes of Job Misery by Patrick M. Lencioni
  • The Coaching Habit: Say Less, Ask More & Change the Way You Lead Forever by Michael Bungay Stanier
  • Carrots and Sticks Don’t Work: Build a Culture of Employee Engagement with the Principles of RESPECT by Paul L. Marciano
  • The Employee Experience Advantage: How to Win the War for Talent by Giving Employees the Workspaces they Want, the Tools they Need, and a Culture They Can Celebrate by Jacob Morgan
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Creativity and Compliance

Stay Weird

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network.

Ronnie’s company, Learnings and Entertainment, utilizes people’s entertainment devices to consume information in their everyday, non-work lives and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies, and resources more accessible.

In this episode, Tom and Ronnie discuss why staying weird in your compliance training and communications is important. By staying weird and using your imagination, you will enhance the user experience and improve your employee engagement with training. Ronnie says it all starts with the business case for compliance training and communications, and with the plethora of training and communications all employees are subjected to, you will have better results going forward by keeping the compliance training and communications fresh.

Resources:

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The Ethics Movement

Converge21 – Viktoria Reding on Employee Awareness, Engagement, and Training


CONVERGE is in its 6th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with like-minded professionals. This year the conference has gone virtual. You will leave the conference with new resources and best practices allowing you to continue the hard work of driving ethics to the center of your business. In today’s episode I visit with Viktoria Reding, Compliance Manager at Wella. We visit about her presentation at Converge21 on Employee Awareness, Engagement, and Training.
For more information, go to Converge21.

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Creativity and Compliance

Using Fictional Characters to Promote Compliance Engagement


Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the Compliance Podcast Network to explore these issues. In today’s episode we are joined by Joel Katz the CCO at Booz Allen Hamilton. Katz was previously CCO at CA Technologies where he gained notoriety for the use of fictional characters in creative programming to promote employee engagement around compliance.
Some of the highlights include:

  • The professional journey of Joel Katz.
  • What was the Griffin Peabody character you created at CA Technologies?
  • How fiction-based characters in compliance training drove the highest employee satisfaction reported in the CA Technologies employee survey.
  • Although the characters were fictional, the stories were based on employees’ personal experiences. This helped drive engagement.
  • All this became a part of a branded communication campaign for CA Technologies.
  • What were some of the key lessons learned by Katz and his compliance team?

Ronnie Feldman
Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)
Learnings & Entertainments (Website)
60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.
Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.
Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.