Tag: training and communications

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Compliance Into the Weeds

Compliance into the Weeds: Szabolcs Fekete and the Consequences of Ethical Breaches

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more thoroughly, looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds! In this episode, Tom and Matt deeply dive into the termination of Citibank employee Szabolcs Fekete over cheating on his expense account, then lying about it and drawing out broad lessons for the compliance professional.

The importance of trust, accountability, and ethics in the workplace cannot be overstated. These elements are the bedrock of a healthy corporate culture and are crucial for maintaining a positive and productive work environment. Tom believes that a broader conversation about these topics is necessary within corporations. He emphasizes the need for employees to understand the importance of trust, accountability, and adherence to policies and procedures.

Matt echoes these sentiments. He shares a poignant story about a CEO who had to fire a cleaner for embezzlement and dishonesty, underlining the critical role of trust in upholding ethical standards. Both Fox and Kelly acknowledge the cynicism among the public and the workforce regarding ethical enforcement, and they advocate for a commitment to doing the right thing, even when it is difficult. Join Tom Fox and Matt Kelly on this episode of the Compliance into the Weeds podcast as they delve deeper into this crucial topic.

 Key Highlights:

  • Expense Report Dishonesty and Wrongful Termination
  • Citibank’s Expense Report Policy and Trust
  • The Consequences of Ethical Breaches
  • The importance of trust and ethical enforcement

 Resources

Matt in Radical Compliance

Jane Croft in the FT

Pilita Clark in the FT

Tom 

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31 Days to More Effective Compliance Programs

One Month to a More Effective Training and Communications – The D&B Experience in Training and Communications

How did one company and one CCO actively use social media to make the company’s compliance culture more effective? The company was Dun & Bradstreet, Inc. (D&B), and its then CCO, Louis Sapirman, discussed D&B’s integration of social media into compliance with me.
As we advance, these tools can go a long way toward enhancing your compliance program. Recall the declination to prosecute Morgan Stanley received from the DOJ when one of its managing directors had engaged in FCPA violations. One of the reasons cited by the DOJ was 35 email compliance reminders sent over seven years, bolsters the annual FCPA training the recalcitrant managing director received. You can use your archived social media communications as evidence that you have continually communicated your company’s expectations around compliance. It is equally important that these expectations are documented.

Finally, always remember the social part of social media. Social media is a two-way communication. Not only are you setting out expectations, but also, these tools allow you to receive back communications from your employees. The D&B experience around the name change for its Code of Conduct is but one example. If you have several concerns expressed, it could alert you earlier to begin some detection and move toward prevention in your compliance program.

Three key takeaways:

  1. How do 360 degrees of communication work in compliance?
  2. Focus on the ‘social’ part of social media.
  3. Use internal corporate social media to have a conversation.

For more information, check The Compliance Handbook, 3rd Edition available here.

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Compliance Week Conference Podcast

Adam Balfour and Brian McAlhaney on Raising Your Communications and Training

In this episode of the Compliance Week 2023 Speaker Preview Podcasts series, Adam Balfour and Brian McAlhaney from Bridgestone/Firestone discuss their Case Study at Compliance Week 2023,  entitled, “From Training to Learning: How We Use Lessons from Star Wars, Jurassic Park and Top Gun to Help Employees Learn About Ethics and Compliance.”

Some of the issues they will discuss in their presentation are:

  • How one company has re-framed their compliance program pillar of “Training and Communication” to “Learning and Engagement” and hear how your program can benefit from their learnings;
  • Tried and tested tips on adult learning, including using experiences, focusing on the impact on the learner, and more; and
  • How creative, effective, and engaging learning can help enhance your ethics and compliance program brand?

I hope you can join me at Compliance Week 2023. This year’s event will be May 15-17 at the JW Marriott in Washington, DC. The line-up of this year’s event is simply first-rate, with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 18th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. And many others to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders, and ethics and compliance visionaries.
  • Hear from 75+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from the two SEC Commissioners, gain insights into the agency’s enforcement areas, and walk away with guidance on remaining compliant within emerging areas such as ESG disclosure, third-party risk management, cybersecurity, cryptocurrency, and more.
  • Bring actionable takeaways from your program from various session types, including ESG, Human Trafficking, Board obligations, and many others, for you to listen, learn and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

I hope you can join me at the event. For information on the event, click here. Listeners of this podcast will receive a discount of $200 by using code TF200 on the link here.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Introduction

In this month’s offering of 31 Days to a More Effective Compliance Program, you will learn about training and communication techniques that the CCO can use to provide a well-rounded role as a CCO and facilitate a much more holistic approach to compliance in your organization. Best of all, the techniques discussed are available at little to no cost. You can do things in your method of running the CCO positions and innovations that you can bring to the compliance function in your organization.

A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is always in touch with and visible to your employees. It is about creating a distinctive brand philosophy of compliance centered on the customers of your compliance program (i.e., your employees). It helps to anticipate all the aspects of your employee’s needs around compliance, especially when compliance is perceived as new, something that comes out of the home office, or as the Land of No. It allows you to build a new brand image for your compliance program.

The objective is to build trust for the 360-degree process by determining if the goal was achieved. You can utilize surveys or focus groups to assess the impact on your target audience. Focusing on your customers of compliance allows you to identify gaps and improve the communication process for your compliance program.

Three key takeaways:

  1. Remember the definition of 360 degrees of compliance communications. It is an effort that moves the compliance identity into a holistic approach so compliance is always in touch and visible to your employees.
  2. What is your objective? What are you trying to do with your 360-degree view of compliance communications, and how are you using that mechanism to deliver the objective your compliance program desires?
  3. You need to evaluate if the message has been delivered, has been heard, and is being implemented.

For more information, check The Compliance Handbook, 3rd Edition, available here.

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Blog

Operationalizing Compliance: Part 4-Effectiveness, Redux

Welcome to a special five-part podcast series on Operationalizing Your Compliance Program, sponsored by Broadcat LLC. Over this series, I visit with Jennifer May, Director of Compliance Advisory; Taylor Edwards,  Director of Sales; Xinia Pirkey, Design Manager; Alex Klingelberger, Chief Executive Officer (CEO) and Jaycee Dempsey, Director of Customer Success. We consider a variety of ways to more fully operationalize your compliance regime, including the design and effectiveness of your communications, why the operationalization of compliance is a team sport, why simply data is not the answer and how to avoid being overwhelmed. In Part 4, I am joined by Alex Klingelberger, where we take a deep dive into effectiveness.

We began with a question about data and data analytics. I asked Klingelberger what might a CEO question a Chief Compliance Officer (CCO) about when the CCO brings data about the compliance program. He explained that it is not simply data but “data, plus.” He would further inquire into such areas as, “How did you collect the data? Who are the people that are involved in the data? What did you ask them? What was the data that you have collected and how it going to prove to both regulators and the business folks how to use it.”

He provided the example of annual compliance training program, where the effectiveness is measured with a “single yes or no question that says, did all the constituents certify that they had completed the annual compliance training program; so that you ended up with a score of 100% completion.” Alex said his first question would be, “what is that worth to us?” This is because the data “simply conveys a unidirectional, transmission of information to the people in the business and you have not necessarily improved the quality of those individuals understanding of their business.”

We also discussed the danger of “patronizing communications”. This is a type of communication which is oversimplified to the point where any person, not just a person who’s working in that business would implicitly understand what is right and what is wrong and therefore know the answer they are supposed to get. Something like “Is bribery bad?” is not something you need to train employees on. What employees need is something more useful which addresses given situations, about what bribery looks like and provides a pattern recognition for employees to avoid it.”

That you are really looking for in effectiveness is engagement. Klingelberger noted it is “instrumental that engagement to form the basis for better bilateral communicating between compliance folks and business folks on the frontline. But it is more than communications up and down, from compliance to employee and back. It is using training and communications to facilitate discussions between employees, their managers, their mentors and others about specific situations; how we should be acting and what things that we should and should not be doing in the course of business.” He believes such discussions are the essence of compliance communications and training.

We turned to the user experience as delivering compliance information in topic focused or risk-based bite-sized pieces, on a more periodic and frequent basis is a better way to deliver compliance training. This can facilitate your employees engaging with not only compliance, but it also engagement with managers and fellow employees so that the communication or training fosters an ongoing conversation on a variety of topics; outside of interactions with the compliance function. “This is the outcome you should desire with your communications or training. Something that is going to engage employees, be thought-provoking or thoughtful; yet if they have a question, they can either raise their hand and contact the compliance function or compliance can direct them to a resource within the company such as on a website or FAQs.”

We concluded by tying back to where we began, with some thoughts on data and effectiveness. Klingelberger considers that effectiveness also informs how compliance should be collecting data and providing it to business leaders. He believes, to the extent possible, your compliance function should “use the same systems and software that your business uses to collect data, to collect your compliance data.” He provided some examples; “if you’re a sales shop, a HubSpot shop, if you primarily work on Excel, maybe those are the systems that you should be using to collect your compliance data rather than a completely separate standalone program that both you and your employees only see once a year and generates limited output.” The key is to “make it easier for your business leader through the data that you are providing them by using data which is familiar to them.”

Join us as we conclude with Part 5 where we discuss how to avoid being overwhelmed.

For more information go to TheBroadcat.com

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Innovation in Compliance

Operationalizing Compliance: Part 1 – Compliance Program Effectiveness Jennifer May

Welcome to a special five-part podcast series on Operationalizing Your Compliance Program, sponsored by Broadcat LLC. We consider various ways to more fully operationalize your compliance regime, including the design and effectiveness of your communications, why the operationalization of compliance is a team sport, why simply data is not the answer, and how to avoid being overwhelmed. In Part 1, I am joined by Jennifer May to consider compliance program effectiveness.

Highlights from this episode include:

·      What is and is not effective?

·      Identify silos and work through them.

·      Compliance is not a closed-book test.

·      Document Document Document

For more information, go to TheBroadcat.com

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Greetings and Felicitations

Great Structures Week II: Structures from Ancient Egypt and Greece and Written Standards

Welcome to the Greetings and Felicitations, a podcast where I explore topics which might not seem to be directly related to compliance but clearly influence our profession. In this special series, I consider many structural engineering concepts are apt descriptors for an anti-corruption compliance program. In this episode 2, I consider the great structures of ancient Egypt and Greece and how they inform the building blocks of a compliance program: Code of Conduct, Policies and Procedures. Highlights include:

  • Greek Column and Egyptian pyramid.
  • What should go into your Code of Conduct.
  • How should your policies be structured.
  • How do implement policies through procedures.
  • Training and communications of Code of Conduct/policies and procedures are mandatory yet complimentary strategies.

Resources

 “Understanding the World’s Greatest Structures: Science and Innovation from Antiquity to Modernity”, taught by Professor Stephen Ressler from The Teaching Company.

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The Compliance Handbook

Effective Compliance Program Hallmark: Training and Communication with Ronnie Feldman and Ricardo Pellafone


Effective Compliance Program Hallmark: Training and Communication with Ronnie and Ricardo
Organizations take measures to articulate their policies and guidelines realistically. Doing this ensures that they can promote their compliance and ethics programs to people with unique positions and obligations by meaningful preparation and exchanging knowledge relevant to them.
However, due to their limited understanding of the hallmarks of effective compliance, specifically training and communication, plus the amount of consideration and attention they provide to it, companies sometimes fall far short of the compliance goals.
While several companies and regulatory agencies assume that they treat the training and communication hallmark well, this is the area they sometimes curve out of their most vital point.
The reasons why most organizations struggle to fulfill the criteria of this hallmark can be:

  • Lack of daily scrutiny and continuing contact
  • For the employee, not ensuring preparation and policy coordination are appropriate.
  • Incorrect or insufficient assessment of preparation and policy efficacy
  • Not giving regard to the risk prioritization of training.

In today’s Compliance Handbook chapter, we’ll dive deeper into the fourth hallmark of effective compliance frameworks: training and communication. We’re joined by two experts in the compliance field, Ronnie Feldman and Ricardo Pellafone.
Key takeaways discussed in the chapter:

  • While training is valuable most of the time, it’s not a tool to an end in compliance. It’s a tool you use to prevent misconduct, but it’s not an end in itself. It fills a unique niche within the compliance officer’s means, but it’s compelling when used for the right purpose.
  • Discover how not to lose trust. Note that if compliance training is boring and preachy, people are annoyed at you for making them go through the experience. As a result, they don’t think well of compliance, which means they are much less likely to speak up to ask questions and report concerns.
  • Analyze who among the players in your organization had to undergo compliance training. Find answers to questions like, “Will the compliance training benefit the regular employee, or it should be those that are in the higher ends—with the authority to either create or control risk?”
  • Training is good, but also consider that people need reminding more than they need instruction.
  • Simplicity and utility are the keys! Your compliance framework should not be extensive and complicated. When things are designed well and they are useful, people will use them.
  • Have you ever been caught in a situation where you’re a manager, you have to approve an invoice from a third party. What are you looking for? That is something that pretty much no one is ever trained on what to do. This is the big difference between the traditional top-down model of training versus the training model used by Ricardo Pellafone. If you want to learn more about this training method, tune in to the chapter.
  • Comedy and entertainment principles can go along with compliance? Sure thing! We like trying new things and discover how well Ronnie blended these elements to create an effective compliance framework.

Order your copy OR copies of The Compliance Handbook: A Guide to Operationalizing Your Compliance Program. Save 25% off. http://www.lexisnexis.com/fox25