Wildly Effective Compliance Officer Tip of the Week - 230
/Big presentation? Board? How to Preview and Pivot for Maximum Success!
Big presentation? Board? How to Preview and Pivot for Maximum Success!
For years the Global Business Ethics Survey (GBES) has provided a wealth of fascinating information. Survey participants are asked to provide insight into the strength of the ethics culture in their workplace, the instances of misconduct they have observed, and what, if any, efforts are underway in their organizations to promote integrity. The most recent report came out recently, and it is chock-full of interesting information.
The GBES includes data from 14,000 employees of a cross-sector of industries surveyed between August 2019 and September 2020. The data is fascinating, as it shows the movement from a stable business environment to one upended by the global pandemic.
The insights from a year like no other give precious information on how employees managed last year, and more importantly, how we can support them going forward.
The Highest Pressure in 20 Years
The highlights:
Employee pressure reached the highest level since 2000. U.S. respondents indicated a sharp increase in employee pressure which indicates employees are experiencing more pressure to violate their organization’s ethics standards than in previous years. This is likely due to the COVID-19 pandemic which caused significant organizational changes.
Observed misconduct surges when employees are under pressure. Consistent with the findings of previous reports, the correlation between the increase in employee pressure and observed misconduct continues to surge upward.
Employee perceptions of retaliation after reporting misconduct escalated to a record high. In the U.S., rates of retaliation have more than tripled since 2013 and globally, they have almost doubled since 2019.
Tripled? Employee’s perception of rates of retaliation has tripled in the US since 2013? That’s terrible, but the good news is that we can help to fix that.
The Interview
I sat down with Dr. Pat Harned, CEO of the Ethics & Compliance Initiative, the organization responsible for the GBES report, to get her advice for compliance officers on what to do to reverse the disturbing trends indicated by the data from the GBES.
KGH: For years the data has shown a correlation between the increase in employee pressure and an increase of observed misconduct. 2020 had the highest scores for employee pressure in 20 years. What was driving this pressure?…
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Read MoreThis is a guest post written by Ramsey Kazem, East Coast Vice President at Spark Compliance Consulting.
Somewhere in the world, it happens every day. There is a catastrophe, and the managers call Compliance in a furious state. As they explain a situation having nothing to do with compliance’s remit, they yell, “Why didn’t you stop this?!? Isn’t compliance your job!?”
Yes, compliance is the job of the compliance department. But question number one always needs to be compliance with what, exactly? If everyone is not clear about the remit of the compliance department, chaos can ensue, with management assuming that compliance with all laws and regulations is the responsibility of the compliance function. How do we avoid this? By spelling out the responsibilities and duties of the compliance function in a Compliance Program Charter. A Compliance Program Charter is a foundational document that defines the program’s scope, purpose, and responsibilities.
Compliance Charter: Setting the Compliance Program Up for Success
The importance of a Compliance Program Charter should not be understated. It serves as an effective tool that articulates to the company what the Compliance Program is and, more importantly in some cases, what it is not. This clarity of purpose sets the Compliance Program up for success for three reasons. First, a Compliance Program Charter defines the program’s purpose, objectives, and lays out the responsibilities for the compliance team in designing and implementing the program. The Charter defines when the compliance team is expected to lead, when they should collaborate, and when they should support other functions.
Second, a Compliance Program Charter ensures that the Board of Directors, Senior Leadership, and other functional areas within the company are on the same page regarding the scope and responsibilities of the Compliance Program. Too often the lines of responsibility for the Compliance Program are undefined or blurred. This leads to confusion and misunderstanding as to which risk areas are managed by the compliance function and where resources should be deployed.
Moreover, in the absence of a Charter, others in the company may view compliance as the default function for all things that look and feel like compliance. This is a recipe for disaster as compliance will be saddled with issues and risk areas it is ill-equipped to manage. A Compliance Program Charter safeguards against this outcome as it forces a meeting of the minds between leadership, compliance, and/or other functions as to where the Compliance Program begins and ends.
Third, a Compliance Program Charter defines the authority with which the Compliance Program and team are empowered. This is essential to the success of the program as the compliance function needs authority to meet its responsibilities. Moreover, defined authority protects the Compliance Program from other functions with an interest in issues and processes for which compliance is accountable.
Key Elements of a Compliance Program Charter
As with most things in compliance, there is no one-size-fits-all solution for creating a Compliance Program Charter. However, the following are some key elements a Compliance Charter should address…
Read MoreLet’s say that you’re the coach of a team in the last moments of the championship game. Your team is behind with little chance of winning. You can choose to say, “It looks like we’re going to lose, but do your best out there!” or “Team, we’re mere moments from victory. We’ll win if we go all in!”
If you think about it, both statements are true. While the team is more likely than not to lose, they could also be just moments from victory. How you frame the conversation will determine how the players see it.
Building the Right Vision
In David J. Schwartz’s timeless classic The Magic of Thinking Big, the author tells readers to “Promise victory and win support. Build castles, don’t dig graves!” Schwartz implores readers to anticipate success and to speak about it as if it were imminent. He stresses that great leaders focus on the expectation of a positive outcome, even if a bad outcome is more likely.
Setting the expectation of success allows people to believe it is possible. This is true both for your team and the business as a whole. If you tell your team that they’ll never get above 50% participation in the Ethics and Culture survey, they won’t be inspired to push the business and to work with the Communication department to come up with innovative ways to get people interested in taking the survey. Likewise, if you tell the business that data breaches are inevitable and a cost of doing marketing, they are less likely to come to you to try to figure out how to stop them before they happen.
Speak positively with conviction that the best outcome is not only possible, it’s probable.
Reframing the Situation
If you find yourself in a difficult situation…
Read MoreWe’ve all been told that using real-life scenarios is the best way to train people, and it’s true! But it’s also true that developing real-life scenarios can take days, if not weeks, and is…hard. That’s where Compliance Competitor comes in. We have drafted huge numbers of base scenarios that can be customized to fit your business. You don’t have to go it alone. Check out www.compliancecompetitor.com to find out more, or email info@compliancecompetitor.com to see a demo.
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