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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: Employee Trust

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 consider how you can work to regain employee trust in the era of remote work and RTO.

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

To check out The Compliance Handbook, 5th edition, click here.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance: Episode 30 — Make a Plan

What happens when two top compliance commentators get together? They talk about compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode!

In this episode, Kristy and Tom discuss various pressing issues and developments in compliance. Topics include the introduction of a new regulator in Europe, concerns of AI employees about retaliation for raising alarms on potential threats, California’s new workplace violence compliance requirements, and unusual attempts to use live animals as payment in Florida.

The episode also highlights the significance of the Women in Compliance conference, the importance of crisis communication strategies, and the recent extension of the sanctions statute of limitations by the U.S. government. The conversation also covers networking for job seekers and the implications of the newly formed European Financial Crime Agency. The episode concludes with a bizarre payment method by our good friend, Florida Man.

Highlights Include:

 Resources:

Kristy Grant-Hart on LinkedIn

Spark Consulting

Tom

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Sunday Book Review

Sunday Book Review: April 28, 2024 Books on Trust Edition

In the Sunday Book Review, Tom Fox considers books that would interest the compliance professional, the business executive, or anyone who might be 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 some of the top books on compliance you should read in 2024.

  • The Book of Trust by Yoram Solomon
  • Building Trust by Josh McQueen
  • Digital Body Language by Erica Dhawan
  • The Four Factors of Trust by Ashley Reichheld & Amelia Dunlop

Resource:

18 Must-Read Books on Building Trust for Your Business and Brand

For more information on Ethico and a free White Paper on ROI for your compliance program, click here.

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FCPA Compliance Report

FCPA Compliance Report – Ron Karr on Influence, Trust and Persuasion

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this special edition of the FCPA Compliance Report, Tom welcomes Ron Karr, long time thought leader in the art of leadership, persuasion and influence. They take a deep dive into the science of influence and persuasion and help the compliance professional understand how they can use this science to move the compliance ball forward in an organization.

Ron Karr is a speaker, and author with over three decades of experience in the sales and consulting industry. His career saw its inception in retail, later transitioning to the computer industry, and eventually culminating in the establishment of his own consulting business. Karr’s perspective on the “Velocity Mindset”, as detailed in his book, revolves around the concept of speed with direction, where goals and aspirations are the key drivers of actions.

His belief that self-imposed limitations can hinder our progress is deeply rooted in his experiences, leading him to emphasize the importance of self-evaluation, proactive approach adjustments, and reshaping our narratives to facilitate our goals. Karr underscores the value of networking and learning from others, seeing it as a vehicle to expedite success and achieve professional velocity.

 

Topics Covered in this Episode

  • Purposeful Reflection for Effective Decision-Making
  • Neurochemical Impact on Influencing Others Successfully
  • Propelling Success through Adaptive Strategies
  • Empowering Personal Growth Through Story Rewriting
  • Enhancing Professional Success Through Peer Engagement
  • The Velocity Mindset: Achieving Success Through Networking

Resources:

Ron Karr on LinkedIn

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The Velocity Mindset

Tom Fox

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

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FCPA Compliance Report

FCPA Compliance Report: Marco Goldberg – Creating Trust with Comprehensive Solutions

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom Fox welcomes Marco Goldberg, Managing Director of EQS Group’s North American Business, which assists organizations in navigating the complex world of compliance and building a culture of trust.

Marco Goldberg is a seasoned professional in corporate compliance and investor relations solutions, with a rich background in international industrial management and an MBA from the Berlin School of Business and Entrepreneurship. The EQS Group is a leading provider of corporate compliance and investor relations solutions, serving about 9,000 customers globally. He emphasizes the importance of trust in international organizations and sees EQS Group’s mission as helping to create trusted companies through their solutions. His experiences in the industry and his active participation in hosting the ECEC, Europe’s largest compliance conference, have shaped his perspective. Join Tom Fox and Marco Goldberg on this episode of the FCPA Compliance Report podcast to learn more about his insights and experiences.

 Key Highlights:

  • Creating Trusted Companies with Comprehensive Solutions
  • IntegrityLine: Empowering Employees for Compliance
  • EU Whistleblower Protection Directive: Creating a Culture of Integrity
  • Centralizing Compliance Workflows with AI Technology
  • The Transformative Power of AI in Compliance

 Resources:

Marco Goldberg on LinkedIn

EQS Group

 Tom Fox

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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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The Circle of Gumption

The Circle of Gumption – Reviving Trust in Society

Zig Ziglar Said,  “I Believe Man was designed for accomplishment, engineered for success, and endowed with the seeds of greatness.” Kenneth O’Neal carries this tradition forward in his work and podcast, The Circle of Gumption, showing how maximizing your God-given talents and abilities leads to a successful, well-balanced existence in all areas of life. Join co-hosts Tom Fox and Kenneth O’Neal as they explore The Circle of Gumption to help change your life mentally, spiritually, physically, financially, and professionally by improving the health of your relationships with others and yourself.

Are you struggling to build trust in your relationships or business? Join hosts Tom Fox and Kenneth O’Neal on The Circle of Gumption podcast as they delve into the importance of trust and integrity in today’s society. In this episode, Kenneth explains how trust is built through care, communication, and consistency, despite the prevalent skepticism in our culture. They also discuss the importance of personal congruence and doing the right thing to rebuild societal trust. He shares a powerful story of a fireman who exemplified integrity and selflessness in his duty, emphasizing how serving others is essential for the betterment of our community. Don’t miss this inspiring conversation on the power of trust and integrity. Tune in now to The Circle of Gumption!

In today’s culture, skepticism is widespread, and people don’t trust easily. However, skepticism is healthy to an extent, especially in the business context, where it’s crucial to have a healthy level of due diligence. But, in building business relationships, trust is essential. One should balance skepticism and trust-building to develop positive, professional relationships.

Three Tips:

1. Show genuine interest in others’ goals and achievements to build trust.

2. Effective communication is crucial in establishing trust.

3. Look for character, competence, and consistency in people to build trust with them.

So, if you want to learn more about the importance of relationships in your life and how to improve your relationships, tune in to this week’s episode of Circle of Gumption. Remember to write down the week’s words and reflect on how you can improve your life through your relationships.

Resources

Kenneth O’Neal

The Circle of Gumption

Tom Fox

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Principled Podcast

Season 8 Episode 13 – Islands of Civility: A Special Edelman Report on Trust in the Workplace

What you’ll learn on this podcast episode

As today’s societal issues continue to mount, employees are turning to the workplace as one of the safer spaces for debate and a primary source of community. Data from a special edition of Edelman’s 2022 Trust Barometer—specifically analyzing Trust in the workplace—note that 78% of employees trust their employer over other established institutions and connections. So, how can companies leverage Trust and adapt their practices to address employee concerns better? In this episode of the Principled Podcast, host Emily Miner explores key findings from the Trust in the Workplace report with David M. Bersoff, the Head of Research at the Edelman Trust Institute. Listen in as the two discuss what drives Trust and how employers can strengthen Trust in—and beyond—the workplace. 

Get a copy of Edelman’s Trust in the Workplace special report. 

Read our blog post on takeaways from this report. 

Guest: Dr. David M. Bersoff, Ph.D.

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Dr. David M. Bersoff

As the Head of Research for the Edelman Trust Institute, Dr. Bersoff is the lead researcher on all of Edelman’s trust-oriented thought leadership, including the Edelman Trust Barometer. He also leads the Institute’s research-based collaborations.

Before joining Edelman in 2016, David spent 18 years as consumer insights and marketing strategy consultant at The Futures Company. In his last 5 years with the organization, he served as its Chief Insights Officer and was a member of its global board of directors. In that role, he ran the Global Insights Group. He drove the research, data analysis, IP creation, and product development strategy for their syndicated consumer insights offers – Yankelovich MONITOR, Multicultural MONITOR, Global MONITOR, Health and Wellness MONITOR, Financial Services MONITOR, and the TRU Youth MONITOR.

In addition to his background in IP development and insights product management, David has also served as a trusted advisor and marketing/brand strategy consultant to major clients in industries as diverse as financial services, automotive, media, professional organizations, energy, and the military.

Before entering the consulting world, David spent 12 years engaged in social science research at various Ivy League institutions, including 4 years as an assistant professor of social psychology and research methodology at the University of Pennsylvania.

Host: Emily Miner

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Emily Miner is a director in LRN’s Ethics & Compliance Advisory practice. She counsels executive leadership teams on actively shaping and managing their ethical culture through deep quantitative and qualitative understanding and engagement. Emily is a skilled facilitator who emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with healthcare, technology, manufacturing, energy, professional services, and education organizations. Emily co-leads LRN’s ongoing flagship research on E&C program effectiveness. She is a thought leader in organizational culture, leadership, and E&C program impact.

Before joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology.

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Blog

A Listening Tour for Compliance

A recent Inc.com article caught my eye about a series of events that returning Starbucks Chief Executive Officer (CEO) Howard Schultz has been engaging in. According to author Justin Bariso, Schultz has been engaging in a “listening tour” of Starbucks stores, literally across America. According to Schultz, he told employees “We are traveling the country, trying to, with great sensitivity, understand from you, how can we do better.” What are employees telling him? Bariso wrote, “he listens intently to one Starbucks employee after another, a pained look comes over Schultz’s face. Employees lament about the lack of training, increased turnover, and extreme pressure they’ve been forced to endure as company profits soared, but worker conditions plummeted.”
This listening tour has several goals for Schultz. The first is that even though the company has sustained record profits, morale at the company is at an all-time low. Witness the unionizing efforts that have been successful. Employees are simply fed up with not being listened to. This has eroded employee trust and management and driven down the once vibrant culture at the iconic institution. In order to rebuild that trust Starbucks, in the form of their CEO, “must first listen.” But it is more than simply listening to rebuild trust, it is rebuilding employee engagement by making them and their ideas part of the solution.
Obviously, there is still much work for Starbucks and Schultz to do. Yet these initial steps can lead to real change. Schultz is doing more than saying “We Care”; he is modeling that language in his behavior. This is action at the top. It is also communicating to other senior management they need to listen to re-engage and to build back employee trust. Now what if a Chief Compliance Officer (CCO) took that same approach for compliance? My belief is that a Schulz inspired listening tour can add multiple benefits to your compliance program.
Engagement
Start off by meeting as many compliance stakeholders as possible. You can use town hall settings, or go smaller, meeting with key employee leaders, key stakeholders and employees identified as high risk who you can meet with individually or in smaller groups. Listen to their compliance concerns and take their compliance ideas back to the home office. After returning to your office, winnow down their ideas and suggestions to form the basis of enhancements to your existing compliance program.
After you roll out your enhanced compliance program with new training, you can then give specific examples of how employee input led to the changes in the enhanced program. This engages the employees and makes them feel like they were a part of, and had a vested interest in, the company’s compliance program. This employee engagement will lead to greater stakeholder buy-in.
Education
But during the town hall meetings, and the smaller more informal group meetings, you can do more than simply listen, you can also train. This training is on overall ethics and how the employees could use compliance as a business tool. Most business’s ethical standards are not found in an existing compliance program, they are found in the general anti-discrimination guidelines and ethical business practices such anti-competitiveness and use of confidential information prohibitions. Often these general concepts can be found in a company’s overall Code of Conduct or similar statement of business ethics; workplace anti-discrimination and anti-harassment guidelines can be found in Human Resource (HR) policies and procedures. Concepts such as anti-competitiveness and use of customer and competitor’s illegally obtained confidential information may be found in anti-trust or other business practice focused guidelines.
All of this gets your employees and other stakeholders to start thinking about doing business the ethical way. It is ethical concept-based training in contrast to a rules-based approach. Moreover, this lays the groundwork for the enhancement of your compliance program and the training that will occur as the enhancement is rolled out.
Risk Assessment
Now think about this same approach from the risk assessment perspective. Listen to your employees concerns and listen to the compliance issues raised. From there you can begin to ask questions about what was done and why. This approach is not adversarial or an interrogation, but it is ferreting out the employees concerns while having the employees educate your compliance team on the actual procedures that are used. By listening, and gently questioning, you should be able to garner enough information to create a risk assessment profile which can inform and even become the basis of compliance program enhancements.
Bariso concluded his article by stating, “People lose motivation when they sense you don’t care. But the simple act of listening creates goodwill. When your people feel understood, they’ll be motivated to contribute and can help you discover insights you wouldn’t otherwise. So, when it comes to solving your company’s biggest problems, don’t ignore your most helpful resource: your people.” It all starts with listening. Let your employees and other stakeholders have the “chance to share their problems, as well as to propose solutions. Meetings like these will reveal key insights, and they will transform your people from employees to partners.”