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As Lao Tzu put it, " the longest journey begins with a single step". The first step in the journey of establishing an adequate communications and traning program is to create an outline for your communications and training approach (Plan). Below is outlined the first step to establishing a Compliance Communications & Traning Program.
Step 1: Plan (to Succeed)
It is tempting to dive right in and to begin drafting the communications and selecting the training that will most likely be involved with the Plan. Don’t succumb.
First, step back and consider the basic questions that will be directly or indirectly involved in whatever Plan you may develop. In a business context, consider:
- What is the company’s business and how and where does it do business?
- How does the company’s compliance program and the CCO’s role support the company’s present and longer term business priorities?
- What are the company’s primary compliance risks, and how does the company’s compliance program address them (or not)?
- What are the messages or themes that we will be communicating, and why?
- Are we introducing any new messages or themes, and why?
- Historically, what have been the most effective ways of communicating with employees and other appropriate parties?
- In what ways do we intend to communicate with employees and other appropriate parties for purposes of this Plan?
In addition to being a good starting point for outlining the communications and training approach, many of these are the types of fundamental questions that a CEO or the board may probe when asked to approve or provide input into a Plan. So best to be prepared.
A mantra that may be helpful to keep in mind throughout the process is “compliance exists to support the business; the business does not exist to support compliance”. Treating this process as a business exercise focused on helping the business, and being open and vocal about this approach, will help achieve the management good will and resource availability that will be critical to making the Plan a success.
The outline should answer the following:
- What are the basic Plan “building blocks”, under the general categories of People, Process, Technology, and Other (e.g. for training, one key element is the company learning management system (Technology); or budget may be required to bring on a new communications tool, such as video vignettes (Other)?
- What will be done (communicated and/or covered by training) over what period of time?
- What is the sequence or roll out of Plan activities, and why?
- What are the assumptions built into the roll out?
Now that you have a plan outlined, you'll want feedback from trusted experts in your organization. Think next about the various colleagues that you want (or need) to get involved to help make the Plan a success. We'll cover this next week in Step 3.
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