The Ultimate Guide to Making Yourself Relevant
/Relevance has become a compliance obsession. If compliance were the fashion industry, then relevance would be the new black. There’s a good reason for this. If compliance isn’t relevant to the employees, it becomes a nuisance. Instead of taking its place as a business enabler, it becomes background noise or a source of friction and irritation. But seeking relevance is quite different from achieving it. What can we do to assure that we’re as relevant as possible to our audience?
Novelist Thomas Berger said, “The art and science of asking questions is the source of all knowledge.” Relevance is achieved through answering the question, “How does whatever it is I want you to do apply in your day-to-day life?”
The Conundrum
Most of us know that we need to talk to the business, but relatively few understand the questions to ask to elicit the information we actually need. The biggest challenge faced by subject matter experts is the assumption that other people know what we’re talking about and can understand why we’re asking the questions we’re asking. Imagine your life before compliance. If someone called you and said, “What interaction does our business have with the instrumentalities of foreign governments?” You’d probably have hung up the phone. We in compliance need to know the answer to this question, but we must ask it in a way that elicits the information we need, instead of scaring and confusing the person talking to us.
The Questions
When it comes down to it, you need to frame the question for the business so that the person can easily give you the information you need. You need to use clear and comprehensible language. Here are some example questions for the most common types of risk areas managed by compliance. Adapt them to your business:
Bribery
How often do we provide gifts, hospitality or charitable donations at the company?
How often do we sell our products to our government or other governments? Is it a large part of our business?
Where do you see our largest risk of bribery within the company?
Antitrust/Competition
How many salespeople/what percentage of the sales team are involved in trade associations?
Do we track this information?
Are we the biggest player in any of our markets?
How do we gather business intelligence on our competitors?
Where do you see the largest risk of an antitrust or competition violation in our business?
Modern Slavery/Human Trafficking
Do we perform any checks to ensure our suppliers aren’t engaging in modern slavery or human trafficking?
Do we use any temporary labor or contractors employed by outside agencies?
Where do you see the largest risk of modern slavery or human trafficking within our business or supply chain?
Conflict Minerals
Do you know which of the products we make requires the use of minerals from Africa or war zones?
How do you obtain the information that we use for our conflict mineral statement?
Where do you see the largest risk of conflict mineral usage in our business?
Trade Sanctions
Do we have sales to countries that might have sanctions issues? These include Syria, Zimbabwe, Yemen, Crimea, Sudan, Iran, North Korea, Libya, Iraq or others about which you’re concerned?
Do we have sales to customers that might have ties to organizations such as the mafia, ISIS, Al Qaeda, or other governments that might give rise to concern?
What do you think is the biggest risk of violating trade sanctions in our business?
Import/Export
Do we have any products that are considered dual-use? (if this term is unfamiliar, try “Do we have any products that might be used as weapons or in weapons, including chemicals or high-tech parts?”)
Do we have sales to any places where there is a war going on?
In what areas of the business might you be concerned with the export of our products where they might get into the wrong hands?
Data Privacy
What types of data do we keep on our customers?
In what ways do we market to our customers? How do we contact them and keep in touch with them?
In what areas of the business do we use the most personal data?
Money Laundering
Where do we use the greatest amount of cash in the business?
What kind of background checks do we do on our customers to ensure they are who they say they are?
Where do you see the biggest risk of money laundering in our business?
Maximizing the Use of the Information
When you get the information, you can use it in a number of ways. These include:
Risk Assessment: You can use the information you receive from the business as the basis for your risk assessment.
Training: You can use the information you receive to help you to create scenarios for your live and e-Learning training courses.
Policies: You can update policies when you find gaps in guidance for responding to risk.
Code of Conduct: You can ensure that the Code of Conduct includes topics that respond to every major risk area. You can also update the Q&A or examples used in the Code to ensure they match the experiences of the people throughout the business.
Communications and Awareness: You can tailor communications to the scenarios presented by the business. You can also choose better imagery that will relate to people’s job functions instead of generic photographs.
Getting the information you need is critical to being effective at your job. Once you’ve got, you can use it to be…relevant – like all the cool kids.
