At last months ComplianceWeek roundtable event in Los Angeles, compliance leaders from a wide array of companies came together to talk shop and provide compliance insights. The panel’s main focus was on how to create a corporate culture that truly values ethics and compliance. The idea herein is that if your employees are advocates for compliance, they will help you advocate compliance to your third-parties and vendors.
It may sound simple enough in theory, but while governance, risk and compliance might be explicitly “your job”– think about your employees. How easy is it going to be to get operations managers, business managers, etc. to take on a side job? Compliance executives at the roundtable expressed the need to identify and mold potential compliance leaders. Potential leaders are not only advocates for compliance within the company, but they should be people that others feel comfortable approaching. Also very important, compliance leaders must know the business. One of the best ways to get other employees on board with compliance initiatives is by bringing compliance to them– presenting them with scenarios of how compliance, if ignored, could adversley affect their business unit, reflecting poorly on them.
While you are molding and empowering your compliance leaders, you cannot forget your actual compliance functions– having systems in place in preparation for misconduct will help you better manage situations that occur. People are not perfect, we will inevitably miss something or will have a rogue employee that just does not care about compliance initiatives. This means we need to make sure that we have not only reactive, but also proactive compliance programs in place. Many of us are probably already familiar with the reactive components of compliance– this is when we have to make changes when something goes wrong! But, let’s also remember that we can be proactive by conducting system audits and monitoring policies and procedures.
Roundtable panelist, Tania Saison, said it best when she said, “It’s not a ‘gotcha’ exercise”– of compliance. She was completely right. To have an effective compliance program you must invest in continuous monitoring, because even if you fix one problem, there might be a completely different problem on the horizon that can’t be dealt with the same way.