No Result
View All Result
SUBSCRIBE | NO FEES, NO PAYWALLS
MANAGE MY SUBSCRIPTION
NEWSLETTER
Corporate Compliance Insights
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe
No Result
View All Result
Corporate Compliance Insights
Home Compliance

5 Strategies to Infuse Compliance Companywide

by Brian Lansing
August 11, 2017
in Compliance, Featured
businessman helping colleagues bridge gap

How the CEO Can Support Compliance

Many executives view compliance as a “check the box” proposition. In this column, LeClairRyan attorneys Brian Lansing and Patrick Hurd argue that a focus on compliance should permeate the entire organization, in much the same way that Amazon obsesses about customer service. It all starts at the top, with the CEO setting the tone.

with co-author Patrick Hurd

Plenty of CEOs “check the box” on compliance. The drill goes something like this: Once a year, the CCO presents the written compliance plan at a board meeting or C-suite retreat. After scanning the checklist of do’s and don’ts, the CEO basically feels satisfied the bar has been met. Time to move on to the next agenda item.

But does checking the box truly protect the company from risk? Does it enhance its business or propel its growth strategy? The likes of Amazon, Apple and Dollar Shave Club have earned kudos for building cultures permeated by a sharp focus on customer service, right down to the smallest interaction. In the same way, regulated companies need to make sure that compliance permeates the organization. The benefits go beyond risk management: A true culture of compliance feels open and honest to everyone it touches; it leads to higher morale, easier recruiting and retention, happier customers and, ultimately, higher productivity. (If this sounds like an overstatement, imagine how it would feel to be at an outfit scandalized by endless sexual harassment claims or embroiled in accusations of “Enron accounting.”) Developing a culture of compliance requires effort, but the concepts are straightforward:

Set the Tone

Setting the right tone starts with the CEO. This does not mean simply honing your message. Fundamentally, it is about integrating compliance into all that you do. The CEO should see all processes in the organization as opportunities to further the company’s culture of compliance, whether they involve the supply chain, operations, facilities, sales, marketing, HR, the board, you name it. How can you prevent costly mistakes? Where could you find opportunities to implement best practices? Have you listened directly to rank-and-file feedback about what’s actually happening on the ground? When it comes to setting the tone, remember that actions matter much more than words (which certainly matter, too). When the CEO makes a visible, daily commitment to compliance, it is easy for everyone else in the organization to follow suit. Consistency is essential. The CEO should set clear expectations and never move goalposts without thinking carefully about the fallout.

Train Your People

Like all other job responsibilities, employees must be trained in compliance. It starts with having a code of conduct, issuing copies to all employees and posting it on the company’s intranet. Consider also posting the code on your outward-facing website to demonstrate your culture of compliance to external stakeholders – customers, suppliers, business partners and the public. But don’t stop there. Train new employees on their first day. Train all employees at least annually. Develop policies and procedures, distribute and post them and train employees on the distinction. Policies have the force of “law” in a company, violations of which subject an employee to discipline, up to and including termination. Procedures are business rules for the company’s operations. Training should include a combination of facilitated in-person training and online training. Take the training yourself, ensure your executive leadership team does, too, and take it seriously. Doing so sets the example for all employees to follow (remember, tone starts at the top).

Build Trust

The CEO and Chief Compliance Officer must have a bond of trust. At a macro level, this starts with the CEO initiating “the talk” — a freewheeling discussion about questions like how to handle incident responses or what the CEO wants with respect to the frequency of compliance-related communications and the level of detail. Some CEOs want to know about any breaches that occur, and ASAP. Others are a bit more hands-off. The CEO should remove the guesswork by communicating openly about expectations with the compliance team.

Be Accessible

Access also matters. The CEO should make sure the CCO and board have an open line for routine reporting and the regular exchange of information about goals, policies, processes and internal investigations. The objective here is engagement, not micromanagement. Regarding communication farther down the line, some companies suffer from disconnects between top execs and mid-level managers who implement compliance programs. In the worst cases, middle managers believe their concerns aren’t being listened to and become millionaires by turning into whistleblowers. The CEO needs to make sure employees at all levels of the organization understand that the brass wants to hear from them. Consider having an anonymous, monitored compliance hotline. This makes employees feel they are a valued part of the company’s compliance efforts. Well-run hotlines can also turn up other matters that may be important to the company. They can help boost morale by contributing to a culture of openness.

Act Quickly

If a compliance issue emerges, the CEO should never wait and hope it goes away. To be sure, the CEO must balance a host of factors, including financial stability, impact on growth and return on investment/profitability. But decision paralysis can be devastating. It is better to act decisively on the recommendations of the CCO, one way or another. In order for CEOs to get the information they need to act swiftly, they need to make sure all parties understand they can “handle the truth.”

In today’s highly competitive environment, it is easy to feel that “now is not a good time” to focus on regulatory compliance. But CEOs cannot afford to be consumed by things like mergers and acquisitions, sales slumps or factory closures. They have to multitask and keep compliance on their radar screens. When companies build integrated, sustainable, mutually trusting cultures of compliance, CEOs would never even think about asking the question, “Why you are bringing this up now?” Nor would the CCO tremble at the thought of raising a compliance issue with a harried CEO. From the top down in such cultures, everyone understands that compliance is a daily responsibility — part of who and what you are.

 


Tags: Code of ConductTone at the TopTrainingWhistleblowing
Previous Post

The Key to Improving Corporate Culture

Next Post

Two Superior Results: Declinations in Linde Gas and CDM Smith

Brian Lansing

Brian Lansing

Brian Lansing is a Senior Counsel in LeClairRyan, based in Richmond, Va. He is the leader of the national law firm’s General Counsel and Secondments team, which provides outside general counsel services and onsite attorney support to businesses of all sizes. His practice also includes compliance, investigations and white-collar criminal defense, intellectual property and technology, commercial litigation, and food and beverage matters.  Mr. Lansing’s litigation experience spans numerous cases in federal and state courts nationwide and before administrative agencies. Prior to joining LeClairRyan in January 2017, he served nearly 12 years as in-house counsel for a Fortune 200 consumer packaged goods company, where he closely managed dozens of anti-counterfeiting, antitrust, commercial, intellectual property, and regulatory cases, and served as legal counsel to the Chief Compliance Officer and compliance department, the corporate affairs and communications departments, the brand and trade channel integrity department, the regulatory affairs department, and the research, development and engineering department. Before that, Mr. Lansing practiced at a Washington, D.C. law firm, where he litigated complex commercial, intellectual property, qui tam False Claims Act, and white-collar cases in federal and state courts around the country and before government agencies. His clients have spanned industries as diverse as banking, communications, construction, government contracting, manufacturing, and services. He has significant experience in business tort, contract, copyright, False Claims Act, fraud, patent, trademark, shareholder, trade secret, and white-collar cases. Mr. Lansing began his career in the United States Navy Judge Advocate General’s Corps, where he handled hundreds of criminal appeals, prosecuted dozens of crimes, and defended dozens of civil lawsuits in federal trial and appellate courts on behalf of the Department of Defense, Department of the Navy, and high-ranking officials. After eight years of active duty he transferred to the Navy Reserve, where he continued litigating civil cases for another six years, and later served as an executive officer and then commanding officer of a JAG Reserve unit, and as special assistant to the Naval Inspector General. He was invested as a military judge in 2012, and currently serves as the Chief Trial Judge of the Navy Reserve, holding the rank of Captain. He can be reached at brian.lansing@leclairryan.com.

Related Posts

2023 EEOC and Employers: Investigating Harassment and Discrimination

2023 EEOC and Employers: Investigating Harassment and Discrimination

by Aarti Maharaj
March 14, 2023

With employment discrimination on the rise, EEOC encourages employers to provide anti-harassment training to their employees and managers and to...

Onboarding Best Practices for Millennial and All Employees

Onboarding Best Practices for Millennial and All Employees

by Aarti Maharaj
March 14, 2023

Reducing turnover and fast-tracking new employees to productivity is a key business imperative. The reality is that about 30 percent...

call of duty activision

Activision Settlement Highlights Where Companies Often Go Wrong With Whistleblowers

by Katherine Krems
March 8, 2023

The SEC has long relied on whistleblowers to enforce securities law, often making it worth their while to the tune...

personnel management

Preparing for Budget Cuts in 2023? Be Sure Personnel Management Isn’t on the Chopping Block

by Vera Cherepanova
March 1, 2023

For compliance departments that need to do more with less, it’s tempting to lean into automated systems. Compliance and ethics...

Next Post
Two Superior Result: Declinations by Tom Fox

Two Superior Results: Declinations in Linde Gas and CDM Smith

Compliance Job Interview Q&A

Jump to a Topic

AML Anti-Bribery Anti-Corruption Artificial Intelligence (AI) Automation Banking Board of Directors Board Risk Oversight Business Continuity Planning California Consumer Privacy Act (CCPA) Code of Conduct Communications Management Corporate Culture COVID-19 Cryptocurrency Culture of Ethics Cybercrime Cyber Risk Data Analytics Data Breach Data Governance DOJ Download Due Diligence Enterprise Risk Management (ERM) ESG FCPA Enforcement Actions Financial Crime Financial Crimes Enforcement Network (FinCEN) GDPR HIPAA Know Your Customer (KYC) Machine Learning Monitoring RegTech Reputation Risk Risk Assessment SEC Social Media Risk Supply Chain Technology Third Party Risk Management Tone at the Top Training Whistleblowing
No Result
View All Result

Privacy Policy

Founded in 2010, CCI is the web’s premier global independent news source for compliance, ethics, risk and information security. 

Got a news tip? Get in touch. Want a weekly round-up in your inbox? Sign up for free. No subscription fees, no paywalls. 

Follow Us

Browse Topics:

  • CCI Press
  • Compliance
  • Compliance Podcasts
  • Cybersecurity
  • Data Privacy
  • eBooks Published by CCI
  • Ethics
  • FCPA
  • Featured
  • Financial Services
  • Fraud
  • Governance
  • GRC Vendor News
  • HR Compliance
  • Internal Audit
  • Leadership and Career
  • On Demand Webinars
  • Opinion
  • Resource Library
  • Risk
  • Uncategorized
  • Videos
  • Webinars
  • Well-Being
  • Whitepapers

© 2022 Corporate Compliance Insights

No Result
View All Result
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe

© 2022 Corporate Compliance Insights

Welcome to CCI. This site uses cookies. Please click OK to accept. Privacy Policy
Cookie settingsACCEPT
Manage consent

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.
Necessary
Always Enabled
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
CookieDurationDescription
cookielawinfo-checbox-analytics11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checbox-functional11 monthsThe cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checbox-others11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-necessary11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-performance11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy11 monthsThe cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
Performance
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Others
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.
SAVE & ACCEPT