Just Because a Policy Exists Doesn’t Mean There Is Compliance

Ethics and compliance professionals have long been aware that a policy by itself is useless. A policy is a simple and necessary first step to set the standard, but it’s the sustained efforts to implement and enforce the policy that leads to actual compliance.

A company may draft a policy, house it somewhere that employees can’t easily find, send a mass email announcement, then consider it “implemented.” This approach may be good enough to satisfy external stakeholders by having something to share with clients or auditors, but does nothing to impact behavior in real life. A sustained implementation effort requires time and resources beyond sending the occasional mass email, an investment that budget holders may not be willing to make. However, without such investment, it’s like establishing a destination but not providing the path to get there.

This happens in law as well. For example, in India, despite its Constitution and subsequent laws over many decades prohibiting discrimination, lower caste Indians are still attacked – beaten, killed, stoned – for wearing the wrong shoes, riding a horse, sitting cross-legged, or changing a name on social media, as reported several years ago by the BBC. Perpetrators often walk away scot-free.

In China, despite various agreements and laws since 1979 protecting intellectual property, enforcement has been (deliberately and strategically, some would argue) lax and uneven. Only recently, perhaps because international pressure has mounted and China has developed enough of its own IP to protect, enforcement is seen as improving.

Of course, having a policy or law is better than having nothing. But it’s only the first step if desired behaviors are the goal. Employees shouldn’t be expected to find themselves to the desintation on their own, and ethics & compliance professionals shouldn’t be expected to bushwhack a path. As corporations declare their strong values and ethical standards, they must also commit to the efforts it takes to support those statements.

What is your company doing to align behavior and culture with policy?

Contact Principle Compliance if you wish to improve the effectiveness of your company’s policies.

Updated from post first published on June 20, 2018