It’s important to recognize that we all contribute to the culture of an organization, a department, or a program area, and that each of us can make a difference over time. So how do we do that?
First, we need to understand that the Compliance and Ethics (C&E) program has eight specific elements defined within the U.S. Federal Sentencing Guidelines. Judges use these guidelines to evaluate the effectiveness of an organization’s C&E program when an organization comes under scrutiny of an enforcement agency for potential non-compliance. Although everyone doesn’t have a part in the design or implementation of all eight elements of the C&E program, we all contribute to the culture and effectiveness of the program.
To be effective, the C&E program must be woven into the fabric of the organization, like a strand of thread within a piece of fabric. We all have a part in that. When a thread is pulled out, the fabric becomes weakened and frays. The same goes for the compliant and ethical culture of an organization when we aren’t all engaged or don’t understand our role and how we contribute. It’s important for everyone to understand that our greatest contribution is to be Collaborative, Informed and Accountable (CIA).
Collaborative: A C&E program must be a partnership to be effective. Silos have to be eliminated to create true partnerships and a “do the right thing” culture. Silos are generally established to keep others out and to safeguard our perceived territories or agendas. That type of outlook undermines the effectiveness of the C&E program, because it creates frays. Henry Ford said that “Coming together is a beginning; keeping together is progress; working together is success.” In other words, together we are better. Collaboration is also a demonstration of respect for colleagues. It shows that we value the skills and knowledge each person brings to the team.
Informed: We need to remain informed of the expected standards and potential risks to our customers, colleagues, ourselves, and the organization’s mission. To remain informed, we must participate in the training and acknowledge the policies assigned to us for review within expected timelines. We need to recognize the value of training and how it helps us reflect, recall, and apply the knowledge about specific requirements that need to be met, why those standards are important, and the consequences of certain actions or inactions. Training gives us the knowledge that equips us to identify potential concerns and prepares us for how to respond to situations.
Accountable: There are times when doing the right thing is unpopular and difficult, and sometimes we may have to do things when we feel afraid. Fear is not a good reason to disregard a situation. When a concern is identified, it’s important to report it so that it is assessed and properly addressed. How would you feel if you didn’t promptly report a safety issue that later resulted in harm to someone? When we identify an actual or potential compliance or ethics violation or concern, it is helpful to consider that knowing and not reporting it makes us culpable (we share in the blame), and that isn’t behaving with integrity or being accountable. If we feel it’s necessary, we can report a matter anonymously through the confidential message line.
Every one of us contributes to the ethical and compliant culture and the effectiveness of the C&E program through our choice to be Collaborative, Informed, & Accountable and essentially, to be agents of CIA.
Deann M. Baker, CHC, CCEP, CHRC
a compliance and ethics newsletter from the Society of Corporate Compliance & Ethics
ISSUE 21, April, 2017 | To subscribe to this newsletter, please click here. Please forward this to your colleagues. Click here to view past issues.