Day 9 of 31 Days to a More Effective Compliance Program

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A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is about creating a distinctive brand philosophy of compliance which is centered on your consumers. In other words, it helps a compliance practitioner to anticipate all the aspects of your employees needs around compliance your employees, who are the customers of your compliance program. This is especially true when compliance is either perceived as something that comes out of the home office or is perceived as the Land of No, largely inhabited by Dr. No. A 360-degree view of compliance gives you the opportunity to build a new brand image for your compliance program.

Previously, I had thought of communications really as a two-way street upward and downward, inbound and outbound, and side to side communications. However, you might choose to phrase it, a 360-degree approach to compliance communications is something different. You simply can no longer as effectively communicate in just two ways. You now communicate in a more holistic manner, and in multiple ways. If you are just thinking about communications in the classic form you are missing something that is happening around you.

360-degrees of compliance communication is not just a classic form of communication but rather it is a communication in the concept of every interaction, whether they be planned interactions or whether they be into or accidental interactions. It is all a form of communication. This is particularly true if you are a compliance professional, a chief compliance officer or a compliant practitioner. The things you do, the way you act, and the way people see you are always communicating. It is not simply communicating to one another as often you may well be communicating to a group across siloed boundaries, to the constituencies with whom you had not even planned to initially communicate.

There are several concepts which should be included in your 360-degree view of compliance communications. Begin with an objective so you identify the purpose of your communication and the target of whom you are going to communicate to. Identify as clearly as you can the purpose and reason to ensure your message is aligned with your objectives. For instance, are you implementing a 360-degree view of communication to educate, inform, change perceptions or build trust and commitment?

Next, who is your audience? To communicate effectively you need to understand your audience. In any corporation, there are multiple audiences who are the key stakeholders in the 360-degree process. How much do they know? Some of the stakeholders include the Board of Directors, senior management, middle management, employee teams, committees, coaches, facilitators, customers, business partners, vendors, sales agents and representative, strategic alliances and business ventures. What are your distribution channels and how do you track your messaging? You should create a comprehensive spreadsheet to track the messages the intended audience and the delivery mechanism. Another key ingredient of the 360-degree approach is feedback. This is a key component of the 360-degree experience and educate each stakeholder on the benefits of feedback from the 360-degree approach.

Finally, you need to evaluate what you have done. You can monitor your communication activities by tracking attendance at the events, website statistics, open rate of emails, downloads of materials, video hits; in other words, the same techniques that your marketing folks would use to determine their messaging’s effectiveness. The objective is to build trust for the 360-degree process by determining if the goal achieved. You can utilize surveys or focus groups to assess the impact on your target audience. By focusing on your customer customers of compliance, I.E. your employees, it allows you to identify gaps and improve the communication process for your compliance program.

Using such a 360-degree approach to communication, allows a CCO to “see around corners” and can be one of the greatest strengths of a best practices compliance program. The reason is listening. Listening is a key leadership component and there are certainly many ways to listen. You can sit in your office and wait for a call or report on the hotline or you can go out into the field and find out what challenges employees are facing. From this you can work with them to craft a solution that works for the company and holds to the company’s ethical and compliance values.

Three Key Takeaways

  1. Remember the definition of 360-degrees of compliance communications. It is an effort that includes the compliance identity into a holistic approach so compliance is in touch and visible to your employees at all times.
  2. What is your objective? What are you trying to do with your 360-degrees of compliance communications and how are you using that mechanism to deliver the objectives of your compliance program.
  3. Evaluate. You need to evaluate three factors: (a) has the message been delivered; (b) has it been heard; and (c) is it being implemented.

This month’s podcast sponsor is Convercent. Convercent provides your teams with a centralized platform and automated processes that connect your business goals with your ethics and values. The result? A highly strategic program that drives ethics and values to the center of your business. For more information go to Convercent.com.

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