Why Your Compliance Program Has All the Elements and Still Isn't Working as Expected
I've spoken with compliance professionals whose programs look to have the right elements – a code of conduct, annual training, a hotline and a risk assessment tucked in a shared drive somewhere. Yet they still face situations in which people don’t behave as they should. The question is why.
Bad Apple, Bad Barrel, or Bad Orchard
When a compliance mishap happens, the instinct is to ask who is responsible. Sometimes the answer is a bad apple. But more often the honest and less convenient answer sits a level or two up, in a team or a business unit that made the misconduct predictable. That's a bad barrel. And every so often the answer is bigger still, in a toxic corporate culture that shaped the barrel to begin with. That's a bad orchard.
The larger the problem, the more difficult it is to fix, and the more systematic approach you need. A forty-page code of conduct, a six-figure compliance platform or extensive mandatory training can’t change behavior if employees don’t know about them, trust them, remember them or suffer no consequences if they ignored them.
Enter change management. I came into this field through a stint in consulting with Ernst & Young early in my career. It is originally an approach built to help organizations adopt a new corporate initiative, be it a reorganization, new system or merger. But because the end game is to change behavior, I realized that the same approach can make an ethics and compliance program more effective in practice.
Six Principles, Borrowed and Adapted
This article is the first in a series that introduces the six change management principles I've applied in ethics and compliance work. These have been field tested over the course of many years in the day-to-day work of running a compliance program:
Clear vision and communication that is positive, inspiring and shared by everyone.
Accountability that requires real ownership and consequences.
Stakeholder involvement that earns allies for the program and overcomes resistance.
Skills development that provides employees with the knowledge and skillset for the desired behavior change.
Metrics that measure not just activity, but what actually matters.
Reinforcing behaviors that makes the desired behavior sustainable and that builds a culture of integrity.
You don't need to become a change management expert to follow any of these principles. You just need to remember that the goal of an effective ethics and compliance program is about influencing desired behavior in people, not producing policies or processes.
Who This Is For
If you've ever felt like your program has every element it's supposed to have and still isn't moving the needle, this series is for you. Over the next several posts I'll go principle by principle, sharing the specific tactics I've used to put each one into practice.
Next up: clear vision and communication, and why a compliance email blast is doing much less than you think.