In this Frontline Interview, Leslie Benton, Vice President of Advocacy and Stakeholder Engagement of the Center for Responsible Enterprise And Trade (CREATE.org), addresses the recent Create.org White Paper, Why Anti-Corruption Programs Fail, Turning Policies into Practices.
In this Q & A, Ms. Benton speaks to the following issues, and where they are not present, a compliance program is at risk:
- Tone in the Middle: Where “the rubber meets the road” in a compliance program, and a significant reason, where it is not robust, as to why compliance programs fail, and fail to get implemented. Why? Because when people have questions or concerns about business decisions, they go to their supervisor’s not “higher up the chain.” Thus, middle managers need to be “empowered to provide the compliance message and to ensure that employees understand what they should do in the context of the risk they face.” Where middle-level managers are not embedded into a compliance program, “one bad message can cancel out all other messaging,” as line managers, more than higher level executives, deliver the message of “what needs to get done” on the front-lines.
- The Profile of the Compliance Function. Compliance needs to be an integral part of the business and needs to have a seat at the business strategy table, as a part of being taken seriously. When compliance is part of the business discussion, it also demonstrates support and visibility to the entire organization. Employees will then see how compliance is a part of business development and has a strong voice in risk assessment. In other words, “it’s a benefit and a part of doing business successfully.”
- Addressing Competing Priorities and Incentives. Employees make difficult decisions in complex environments and at some level, “they were hired to grow the business.” In the field, they can face tremendous pressure to skirt the rules in order to get the job done. Thus, forward based personnel need to understand that “compliance is part of doing the deal.” Incentives can put them into an untenable position, so compliance has an important role to help employees understand “that they will always benefit from doing the right thing.” How? By “compensating you to behave as we expect you to behave.”
- Communication and Training. It is “vital that employees are receiving the compliance message from every level of the company.” As shared at a recent compliance symposium “ten minutes with the CEO is worth forty hours of training.” Training is critical to “creating a culture of integrity, and “atmosphere of openness and transparency.” Compliance leaders need to “show vulnerability and be open as human beings.”
In the concluding part of the interview, Ms. Benton addresses practical steps for implementing a compliance program, which include, “commit, communicate and embed.” In this segment, Ms, Benton speaks to the importance of:
- Leadership commitment to embedding ethics and compliance across the company. Compliance needs to become “a part of the company DNA that’s supported by policies and procedures.”
- Employees embracing training as a way to help them do their job, and that it is embedded into the business process.
- Thinking about the corruption risk that you face and that “it’s not one size fits all” in terms of risk and compliance solutions.
- Having compliance right size a program and to make certain that it is “calibrated to the risk that you face.” In other words, “Look at your highest risk and make certain that the program fits and addresses those risks.”
In sum, as Ms. Benton concludes, “People like to work with companies with integrity and it leads to greater success.” Why not take advantage of best practices, lessons learned, and think about how your program can be indexed to these issues via this Create.org White Paper, which can be downloaded from the Create.org website at www.create.org