If Your Company Were a House, the Ethics and Compliance Program Would Be the Roof
Caveni Wong

Is Your Compliance Training As Effective As a New Year’s Resolution?
Caveni Wong

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

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

Training and Policies Are Not Enough to Prevent Unethical Decision-Making
Caveni Wong

How Remediating a Roof Leak is Like Responding to a Compliance Breach
Caveni Wong

If the Law is the Hammer, What Else is in Your Compliance Toolbox?
Caveni Wong

Bobby Pulido is running for a congressional seat in South Texas and realized he wasn’t breaking through to voters. Busy families weren’t watching political debates or scrolling campaign websites. They were at quinceañeras, celebrating their daughters’ fifteenth birthdays, dancing and eating. As a well-known musician, he had an idea. He made an offer to perform at these celebrations, and within the first 24 hours, he received more than 1,000 requests.

This is exactly what I did to get people’s attention in my last role. I sought invitations to join staff meetings and business unit townhalls instead of demanding separate meetings. I made my appearances short and punchy, usually with a little humor thrown in. I aimed to build relationships and trust with leaders and employees by showing up in places where they were already going, physically and virtually.

Ethics and compliance professionals face the same fundamental challenge Pulido did. The employees we most need to reach are not seeking out compliance messaging. They are busy, distracted, and operating in a world where our messages compete with everything else demanding their attention. To get across, we need to meet employees where they are rather than where we wish they would be.

What Pulido did intuitively is something change management practitioners have understood for years. To change behavior, you have to understand your stakeholders, build trust, and reduce resistance. Showing up at quinceañeras signaled that he understood what voters actually cared about and made it easy for them to hear his message. Showing up in staff meetings and townhalls sent the same signal to employees: I will come to you. That single shift builds more goodwill than any standalone compliance event ever will.

For E&C programs that struggle to connect with middle management and employees, this is where I would start. Where are your people already gathered? Go there first.

Meeting Stakeholders Where They Are: A Change Management Lesson for Compliance from an Unlikely Source
Caveni Wong