Is Your Compliance Program going on Summer Holiday, too?
By GAN Integrity
Compliance programs are human driven, meaning that they are shaped and operated by a single individual or by a limited group of persons – often with large responsibilities and limited resources. Our clients (for example, international, publicly listed companies) are typically understaffed when it comes to compliance, with no more than 3-4 FTEs taking care of the program, on average. But what happens during the summer holiday period, when key compliance personnel are away?
The reality is that compliance operations often slow down or stop, as well. And when key compliance personnel come back from holiday, it takes a couple of weeks to get up to speed again. As a result, a company may miss up to 2 months per year of compliance activity due to the holiday absence of the organization’s key compliance people. Couple that with different holiday seasons in the world regions and with the occasional void left by key compliance people leaving the organization and new ones coming on-board, and a compliance program’s operation may be effectively out of action for several lengthy periods during a year.
Keep your compliance program alive while you are away
So, how can you maintain dynamic compliance program activity during these periods, and therefore have a more effective and consistent compliance program? An automated approach to program operations can solve this problem. With such a program in place, one can assign compliance tasks in advance—the system will then monitor and follow up on those for you while you are away. A change of compliance personnel will also not disrupt a program’s operation, as the automated processes that have been set in motion will continue until a new compliance person is in place.
A further benefit of having an automated system support a compliance program is that you can appoint a person from a lower level within your department or from another department to supervise program activities in your absence. He or she is able to monitor and follow up on the basic program activities (e.g. emailing a previously written and approved anti-corruption compliance policy reminder to sales personnel and agents in a high-risk location) with very little training or knowledge required on compliance processes.
Let the software do the work
An automated approach does not suggest that the human element is eliminated in compliance operations. Compliance managers are still the brains behind the automated compliance program: They set risk levels, draft the content to be delivered by the automated platform, specify the periods to lapse between compliance task iterations, analyze the data produced by the system, and so on. But, with the compliance manager as the brains behind the program, let the automated system’s software be the muscle doing the hard and repetitive work. Your company’s program will continue to operate meaningfully in your absence, and you will then spend a more relaxed holiday where you do not have to worry about day-to-day compliance operations.
The not-too-distant future will bring an automated compliance system that will assist compliance personnel with compliance-related analyses. “Business Intelligence” elements applied to compliance will add even more capabilities and quality to compliance program operations, with likely features including the ability to highlight discrepancies, raise red flags, and suggest different response options. Until then, enjoy your summer holiday while your automated system handles certain basic but important program management tasks on your behalf.
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