A word on integrity
Integrity, once laconically described as ‘doing the right thing even when no one else is watching,’ is arguably the most important facet of company culture that operates to deter deviant, unethical, and potentially illegal behavior. Nonetheless, creating a culture of compliance is no easy feat. Despite insistence by regulators and enforcement authorities that the existence of such a culture is a fundamental aspect of demonstrating compliance program effectiveness, the large majority of organizations pay little heed to the cultivation of habits that consistently lead to ethical outcomes.
A major impediment to fostering a culture of compliance is clear and consistent communication.
While many companies are accustomed to articulating these values in the context of an employee handbook or code of conduct, they routinely fail to emphasize—and reinforce—the significance of these mores in employee interactions. This is especially true during initial employee orientation, where discussion of an organization’s compliance expectations are relegated to the periphery, in favor of other, ostensibly more “practical” considerations.
The most effective organizations recognize an ethical culture is a core operational consideration.
Such organizations realize an ethical culture can either undermine or sustain competitive advantage. They place a premium on ethical behavior as the key to unleashing the company’s full potential within the framework of regulatory requirements and respect for the rule of law. These companies avail themselves of opportunities to communicate compliance information on a direct, one-to-one basis.
Ethical culture often begins with partnership between Human Resources and the compliance function.
In the context of initial employee orientation, it is not uncommon for the compliance function to partner with the People or Human Resources team to lead new employee induction. This allows senior compliance officials to articulate the organization’s ethical expectations up front, and perhaps most importantly, give the compliance function both a face and a name.
Empirical and anecdotal evidence strongly suggests that these initial outreach efforts are key differentiators between companies that pay lip service to compliance, and organizations that are indeed “compliance-conscious.”
1
Sustain your ethical culture by maintaining multiple channels to receive employee feedback. This is often called the “speak-up” attribute of a culture of compliance.
2
Empower employees at all levels to raise concerns that implicate a company’s code of conduct or a potential legal or regulatory infraction without fear of reprisal.
3
Reiterate and reinforce ethical principles through dialog with senior leadership, opportunities for employee surveys, and conversations with the compliance team.
Integration
Integrate compliance with operations
The most effective compliance programs completely integrate their compliance teams into the operational processes at the heart of the company’s business activities. This includes allowing the compliance function to operate in the proverbial trenches rather than being confined to the C-Suite.
Partnership
Facilitate timely concern resolution
Evidence strongly suggests that the most effective compliance programs are those in which the compliance function itself is viewed as a partner rather than a piraya—actively facilitating resolution of employee concerns and engendering real trust and respect.
Speak-up
A speak-up culture is proactive
The benefits of maintaining a “speak-up” culture are acknowledged in industry literature, government commentary, and regulator expectations. Foremost among these is the ability to detect potential malfeasance before it occurs and to solicit employee feedback crucial in mitigating emerging risks.
GAN Integrity helps organizations focus on building a culture of compliance by offering a state-of-the-art integrated compliance management solution to companies both big and small. Among other things, GAN Integrity’s platform:
- Facilitates employee reports of potential ethical infractions and legal violations;
- Promotes transparency by making critical compliance information available to stakeholders throughout the organization;
- Drives efficiency by consolidating information into a single space.
By eliminating the need to utilize multiple platforms or rely on manual processes, GAN Integrity’s platform also allows compliance officers to focus on more proactive measures aimed at building—and sustaining—an ethical organizational culture. In an era of significant budgetary constraints, this efficiency is a necessity, rather than a luxury, for compliance teams faced with an increasingly complex and demanding workload.
