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31 Days to More Effective Compliance Programs

Day 9 – 360 Degrees of Compliance Communications

A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is about creating a distinctive brand philosophy of compliance centered on your consumers. In other words, it helps a compliance practitioner to anticipate all the aspects of your employee’s needs around compliance.

This is especially true when compliance is perceived as something that comes out of the home office or as the “Land of No.” A 360-degree view of compliance allows you to build a new brand image for your compliance program. This is important as the 2020 Update mandates that for a compliance program to be effective, it must be understood by various stakeholders.

Communication is often thought of as a two-way street, upward and downward, inbound and outbound, or side-to-side. However, it is better to think of it as a 360-degree effort. You can no longer effectively communicate in just two ways. You now communicate in a more holistic manner and multiple ways. If you are thinking about communications in the classic form, you are missing something happening around you.

360 degrees of compliance communication is not just a classic form of communication but communication in every interaction, whether planned or accidental. It is all a form of communication.

This is particularly true if you are a compliance professional, practitioner, or CCO. The things you do, the way you act, and the way people see you, you are always communicating. It is not simply communicating one-to-one as often you may be communicating to a group across siloed boundaries, to the constituencies you had not even planned to communicate with initially. It also allows you to see and hear new ideas, concepts, or ways to create a more effective compliance regime for your front-line BD folks and your first line of defense.

Three key takeaways:
1. Remember the definition of 360 degrees of communication. It is an effort that moves the compliance identity into a holistic approach, so compliance is in touch and visible to your employees at all times
2. What is your objective? What are you trying to do with your 360 degrees of communications, and how are you using that mechanism to deliver the objectives of your compliance program?
3. Evaluate. You need to evaluate three factors: 1) has the message been delivered, 2) has it been heard, and 3) is it being implemented?

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The Compliance Life

Louis Sapirman – How can communications be used as a driver of culture?


The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Louis Sapirman, Vice President, Chief Ethics & Compliance Officer and Chief Compliance Counsel for Panasonic Corporation of North America, the principal North American subsidiary of Panasonic Corporation. He oversees the company’s regulatory and compliance function, maintaining a culture of ethics, and ensuring all employees are upholding Panasonic’s longstanding values in their work.
Louis previously served as Associate General Counsel & Chief Compliance Officer for the Dun & Bradstreet Corporation. During his tenure as CCO, the company was recognized as one of the World’s Most Ethical Companies by the Ethisphere Institute. Prior to moving in-house, Louis worked in private practice with several law firms including Wilmer Cutler Pickering Hale & Dorr and Buchanan Ingersoll. Throughout his career, Louis has been recognized for his work. In both 2015 and 2016, the Ethisphere Institute named him to their list of Attorneys Who Matter in Compliance and Ethics, and in 2010 he was named International Employment Lawyer of the Year by the Association of Corporate Counsel.
In this Episode 3, Sapirman discusses how communications can be used to help drive a more ethical culture. Sapirman believes that communication as a driver of culture. But more than simply being a great communicator, a compliance practitioner must use skill to help others communicate the messages of ethics and compliance. He discusses the concept of 360-degree communications. He is a big fan of social media and the power of non-verbal communications. He concludes with an example of how he used training as an effective tool of communications.

Categories
The Compliance Life

Louis Sapirman – The Personal and Professional Journey of a CCO


The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Louis Sapirman, Vice President, Chief Ethics & Compliance Officer and Chief Compliance Counsel for Panasonic Corporation of North America, the principal North American subsidiary of Panasonic Corporation. He oversees the company’s regulatory and compliance function, maintaining a culture of ethics, and ensuring all employees are upholding Panasonic’s longstanding values in their work.
Louis previously served as Associate General Counsel & Chief Compliance Officer for the Dun & Bradstreet Corporation. During his tenure as CCO, the company was recognized as one of the World’s Most Ethical Companies by the Ethisphere Institute. Prior to moving in-house, Louis worked in private practice with several law firms including Wilmer Cutler Pickering Hale & Dorr and Buchanan Ingersoll. Throughout his career, Louis has been recognized for his work. In both 2015 and 2016, the Ethisphere Institute named him to their list of Attorneys Who Matter in Compliance and Ethics, and in 2010 he was named International Employment Lawyer of the Year by the Association of Corporate Counsel.
 In this first episode, we consider Louis’ personal and professional journey into the field of compliance. We get to know Sapirman through his family and why he is so passionate about compliance, institutional justice and institutional fairness. We learn about two experiences growing up that helped informed his views on diversity and the wider world. He talks about his experience as a member of a service fraternity in college and then moves into his professional career. His legal work as a Generalist into Employment Attorney, moving to Employment and Litigation work at D&B and then revamping the investigations process at D&B.