Part one of this series dealt with the question of why compliance is so important. This chapter (part 2) I explore how to cultivate a compliance culture and embed the appropriate principles in a broader company culture.
Once you have your compliance framework in place you are faced with the question as to how do you ensure that everyone is aligned and does in fact comply? How do make your policies and procedures as natural as part of the daily work life in your business as breathing?
That is where you want to be. If your policies and procedures forms such a natural part of your business, your compliance becomes agile and the business can go with the flow so to speak, irrespective of whether the flow is new legislation or new risks.
The old saying of the tone is set from the top still rings true. If you don’t have buy in and show commitment from your board or senior management, and if your board and senior management do not walk the walk, that is demonstrate compliance through every day consistent action, then the rest of the team will simply follow their lead, and compliance will be seen as just a tick list exercise for the compliance department or an item on the board meeting agenda instead of being embedded in company culture and values.
A well thought out/worded policy and procedure means nothing if it is not applied. To this purpose, it is important that staff are made aware of any new policy and procedure or any changes to existing ones.
To run an effective training programme, it is important that you know your audience. For one, various pieces of legislation may require either formal training sessions with accompanying assessments and others may deem awareness campaigns as sufficient. An awareness campaign can include, for example, distributing infographics or putting up posters. Secondly, you also need to vary your training methods. Some employees will retain better if they are able to work through interactive material, whereas others may prefer a classroom setup. In all instances frequency is key: one source indicates that employees will forget 50% of training material within one hour and up to 70% within 24 hours after a training session1.
I have found hat one of the biggest enemies to building your compliance culture is fatigue. There is a thin line to tread between raising awareness on a specific topic and a topic so frequently discussed that the mere mention thereof queues rolling eyes and deep sighs. When employees have heard about a specific topic too many times, they simply stop listening and the very important message then gets lost and is a waste of valuable resources.
A well thought out/worded policy and procedure also means nothing if your software or cloud-based products do not support this. Whether it is your CRM system or you KYC platform, the policy that enables the procedure and which describes your control measures must be enabled through the applicable software or platform. Employees should not be able to override or circumvent these controls embedded in your software or platform. Practice has shown that where it is possible to override built in controls, trouble follows. The use of technology can also enable your compliance team to:
- Use their time more effectively
- Enhance training efforts
- Enable a more focussed approach
- Enhance research capabilities
- Ensure efficient monitoring, etc.
One of the skills that a compliance officer must learn, is change management. It is all about changing people’s perspective. Changes in policies and procedures may come with concerns from employees regarding adding to their workload, uncertainty of what is expected from them, or just simply fear of the unknown. This can be managed through an effective training programme. Engaging with employees on a topic can also provide employees the opportunity to voice concerns, provide valuable feedback to the compliance team and allay employees’ fears. This feedback can also help the compliance team to drive continuous improvement.
The biggest motivator to driving a compliance culture is probably in understanding why you do what you do. More often than not it is not only about dotting the i’s and crossing the t’s in order to ensure compliance with legislation, but there is a bigger driver of changing the world for the better. The why is out there, you just have to look for it.
How has compliance affected your life? Would you benefit from discussing the topic further? Connect with Marianne Mokken on 021 819 7813 or mmokken@wauko.com to share your thoughts.
