No-Fail Events to Take the Pulse of Your Compliance Program

Risk Assessments and Culture of Integrity Surveys vs. Pulse Check

I bet you already have a fancy risk assessment and have been utilizing culture of compliance/integrity surveys to get feedback from your business for quite some time now – enough to see year-on-year trends, even. These surveys and assessments certainly have their place, but they can be time consuming to implement and analyze, and of course they require buy-in from the business.

I recommend a “pulse check” at an annual compliance week event, in which the company dedicates a week of focus on the compliance function and program and often incorporates fun activities and events such as a compliance fair in the festivities.

The benefit of a pulse check at an annual compliance event is that it’s an immediate, focused indicator of what you need to know; and the best part: you don’t need to persuade your colleagues to participate. They will be literally lining up to give you juicy information to improve and better direct your compliance program efforts.

Because playing games at these events doesn’t feel as serious as a risk assessment interview, staff may give more candid feedback – which can be very reliable for actioning future initiatives.

So, how do we do this?

Depending on what information you’re seeking and how to you intend to use it, there are several ways to use your compliance event to inform your upcoming efforts and attention.

Where possible, keep it themed. Last year, we did a carnival theme; this year, the theme was rodeo. At each event, there were several activities tied to the theme, and the following feedback mechanisms were woven into those activities:

To determine whether you’re succeeding as a business partner and true enabler of business, set up a simple easel with paper and markers and ask staff to write the one word that comes to mind when they hear “Compliance.” It will give you an idea as to perceptions of the staff, and you can hand out candy, stickers or a compliance-related, company branded item in conjunction with collecting this feedback (“Cheers to Compliance!” on mugs, for example). Of course, nothing so lavish as to influence the comments!

Similarly if you’re looking for general feedback, set up the easel and ask, “How can we serve you better?” A lot of the time, the feedback coming in will be on the success of your education program and ideas for improving it; this can be pretty handy, as it doesn’t make sense to roll out a whole “culture of integrity” survey just to get feedback on how the program is being received. You’ll also get some good “food for thought” feedback, which can be put on the agenda for your next department meeting. There is a lot of room for flexibility in what you ask to learn about how your compliance program is being received.

For more focused inquiries, such as identifying whether your annual training content has “stuck” five months on, or whether you need to go back to basics, try quiz-related activities. Examples include:

• A Jeopardy-style contest is great for staff unable to attend in-person activities. Review your annual training and select key takeaways, then position them as quiz questions for your Jeopardy game.
• Include lucky draw prizes, of course! These can be relatively inexpensive – we bought Amazon Echo Dots on sale last year and used them as giveaways and got a lot of feedback about how the prizes were cool. (Wow! They’re practically saying we in compliance are cool!)
• Create a ring-toss game in which players must correctly answer compliance quiz questions to earn rings to throw. In the version we played last year, participants threw rings over wine bottles for a chance to win a bottle of wine.
• This year, we’ll have a spin-the-wheel game with the seven elements of an effective compliance program on each sector and relevant questions for each.

To test whether you are all set on the basics and to identify whether there are some gaps yet to be bridged, try quiz questions with the most basic answers you can think of. These should be questions almost all staff will know the answer to. For instance, “who is the Chief Compliance Officer?” “What is the compliance hotline?” “Where can you access the code of conduct?” and so on. I guarantee you’ll be so shocked with some of these answers that you’ll have a great starting point for a gap analysis after just a few dozen people have played the game.

Using Your Data

These temperature checks are certainly not designed to replace aspects of your compliance program, such as your risk assessment or the quiz at the end of your annual training. They can, however, be helpful in understanding how to address gaps or increase communication with your business.

You may assume your compliance program excels in certain areas that a quick pulse check indicates are sorely in in need of improvement – whether using a different format to cover annual training topics that have recently reviewed but not retained, creating a podcast interview or new blog series with your Chief Compliance Officer and communicating with the business through methods they’ll actually engage with.

Pulse checks can be sobering activities, but the kind of information they can provide is key to ensure you have more than a paper program, that you’re in touch with your key constituents and that you’re intent on being a good business partner.

Plus, you’ll be collecting this data from colleagues in a fun environment, where they’re not feeling scrutinized or in trouble for giving the “wrong” answers, and you get immediate feedback from colleagues who are excited about participating.