Gatekeepers: Safeguarding the Keys to the Compliance Kingdom

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Gatekeepers: Safeguarding the Keys to the Compliance Kingdom

The following is a guest post written by Diana Trevley, Chief of Global Services, Spark Compliance Consulting

The Department of Justice’s recently released Evaluation of Corporate Compliance Programs Guidance Document (“Guidance”) provides prosecutors with a list of questions to consider asking when investigating a company’s compliance failures and determining whether to bring charges.  By publishing these questions, the Guidance also provides companies with specific information on what actions, taken together, constitute an effective compliance program.  Included in the document are three questions about gatekeepers:

“Gatekeepers – What, if any, guidance and training has been provided to key gatekeepers in the control processes (e.g., those with approval authority or certification responsibilities)? Do they know what misconduct to look for? Do they know when and how to escalate concerns?”

This has some compliance officers wondering, what, pray tell, exactly is a gatekeeper?… 

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Metrics that Matter: Part 7 – Communications and Tone from the Top

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Metrics that Matter: Part 7 – Communications and Tone from the Top

George Bernard Shaw had it right when he said, “The single biggest problem in communication is the illusion that it has taken place.”  Communication is a critical part of a compliance program.  After all, without communication, how would anyone know the program even exists?  And perhaps more importantly, without communication from the top management (and middle management), how would anyone know that the managers support the compliance program? 

In this blog, we’re going to explore metrics relating to communications and tone from the top.  This is Part 7 of our series.  If you haven’t read Part 1, I recommend you go back and start there, as it sets the stage regarding why certain metrics should be chosen.  We’ve already explored metrics that can be used with policies and procedures, which can be found HERE, monitoring and auditing, which can be found HERE, training, which can be found HERE, third-party risk management, which can be found HERE, and governance, which can be found HERE. 

What Should We Measure?

When it comes to metrics relating to communication and tone from the top, there are three things you should measure….

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How the 10/5 Rule Can Make You Wildly Effective

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How the 10/5 Rule Can Make You Wildly Effective

If you’re ever lucky enough to stay in a Ritz-Carlton hotel, you may think it’s the plush towels and comfy bedding that make the place so special.  While that’s nice, the reason so many people revisit the hotel chain has more to do with service than with swimming pools.  How does the Ritz-Carlton ensure that its service is consistent across the world, and that each of their employees makes people feel good?  Simple - the Ritz-Carlton hotels franchised a policy called the 10/5 Way, which has made all the difference for their brand.

What is the 10/5 Way?

The 10/5 Way is easy.  When a guest is 10 feet from a Ritz employee, the employee is to make eye contact and smile.  When the guest is 5 feet away, the employee is instructed to smile and say “hello.”  Does this make a difference?  Sam Walton of Walmart and the staff at Ochsner Health System knows it does. 

When Sam Walton, the founder of Walmart was in charge, he required his greeters to smile whenever they were within ten feet of a customer.  It was part of what made the company so successful in its rise. People were surprised to be greeted by a person.  When a person feels welcomed and thanked for visiting, they feel important. 

Case Study: Ochsner Health System…

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How to Choose Metrics that Matter Part 6 - Governance and Oversight

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How to Choose Metrics that Matter Part 6 - Governance and Oversight

“A focused Board concentrates on strategy, oversight and governance practices, to avoid getting lost in the forest,” said Pearl Zhu, author of the Digital Masters series.  There is much consternation over the role of the Board of Directors/Audit Committee.  Boards are tasked with setting corporate culture and the tone from the top, often without instructions for how to actually do that.  One key way Compliance can help is to provide the Board with useful metrics.  Those metrics should include a mirror of how involved the Board  and Top Management (C-suite) is with Compliance, and how supportive top management has been to the program as a whole.   

In this blog, we’re going to explore metrics relating to the governance and oversight of the program.  This is Part 6 of our series.  If you haven’t read Part 1, I recommend you go back and start there, as it sets the stage regarding why certain metrics should be chosen.  We’ve already explored metrics that can be used with policies and procedures, which can be found HERE, monitoring and auditing, which can be found HERE, training, which can be found HERE, and third-party risk management, which can be found HERE.

What Should We Measure?

When it comes to metrics relating to governance and oversight, there are three separate types of metrics….

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