CCI columnist and compliance author Mary Shirley shares the most resonant writings of fellow CCI columnist and compliance author Adam Balfour from his new book, “Ethics & Compliance for Humans.”
I was very fortunate to receive one of this year’s most coveted items in the ethics and compliance space — my very own signed copy with dedication of Adam Balfour’s new book, “Ethics and Compliance for Humans: Building the E&C Program Your Employees Deserve.”
Three points in particular have stuck with me since reading Adam’s excellent book.
The human factor
Adam’s overarching theme is that the only way forward is to treat our stakeholders as the humans they are, and he shares his ideas for how we can do that most effectively.
A big part of this shift in our space comes from a change from rules-based to principles-based compliance programs and the idea that we don’t have ethics and compliance programs because we have to and we’re scared of getting into trouble but that we have a shared set of values about the right way of doing business and we need reminders and clarity about those expectations. After all, as humans, we are all fallible. So as ethics and compliance (once known simply as compliance) evolves, so too should our approach.
Some of my tips for keeping a human-centric approach in mind are:
- Allow your authentic self to show through, especially if you’re a bit kooky. Frankly, we’re all a little weird and it’s admirable to bring a bit of that to the workplace. A long time ago, a rather serious British lawyer commented on me being my genuine self, “You’re very disarming, you know.” I took this to be a huge compliment and I think in compliance we can never be too disarming and pleasantly surprising to our colleagues. (I might make my goal for next year to surprise and delight my internal customers.)
- Provide transparency and de-mystify compliance. Talk openly about what can be expected in an investigation process. Walk through the rationale of your advice to the business. Share some of the commentary that goes through your mind that acknowledges hard truths — and don’t deny the fact that certain aspects of the compliance program add more time and effort to your colleagues’ workload. Keep your credibility by acknowledging their legitimate concerns. Championing compliance does not mean wearing rose-tinted glasses.
- Focus on advocacy and outreach by having as proactive a compliance program as possible. A lot of companies still don’t run compliance week events or compliance fairs. Think about what more you can do to increase favorable compliance interactions within the business and talk to workers human-to-human. Here’s a good way of determining whether your program is proactive: If the only time the business comes across you is for an audit, risk assessment, investigation or training, that means there’s room for improvement.
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Read moreWrite policies the business can and will refer to and read
Adam is a strong proponent of user-friendly policies. And rightly so. If no one reads them, what’s the point of having policies in the first place? Struggles often come about because the company wants to protect itself legally and feels the best way to do that is to throw everything, including the kitchen sink, into compliance policies.
This is one of the reasons I get so confused when companies appoint someone from their legal team without a compliance background to be their chief compliance officer. How are they supposed to know how to switch from intense focus on defending the company, including when it comes to how policies are drafted, to what is needed to be an effective compliance officer?
Some of my preferred ways to make policies more user-friendly:
- Incorporate learning aids like FAQs and/or scenarios.
- Have policies laid out so that they’re easy on the eye. Just say no to screeds of bunched-up Times New Roman with zero images. Consider an infographic layout for certain policies, and try to use photos of real employees whenever possible.
- Use review tools designed for identifying whether a piece of text is appropriate for a reading level, for example, no more complex than an eighth-grade reading level. Pro tip: Get a young adult of your chosen reading-level age to give you a candid review of what they can and can’t understand, as well as providing general feedback on content that will be for public consumption, such as a revised code of conduct.
Just be a good dude
This isn’t precisely in the book, but I’m taking liberties here. Adam is a classy, gracious guy. He is principled and kind. The sort of person that people in the business are inclined to react to positively: “Egads, it’s another compliance training, but I know this came from Adam’s team and I like him, so I’m just gonna suck it up and do this to help him be successful. He’s a good dude.”
Ethics and compliance needs likable folks. And honestly, I think that’s one of the hardest parts of what we do: Staying true to our principles and sticking to our guns while still being considered a fair and helpful colleague. I don’t know if I’ve mastered this yet. But with friends in the space like Adam, dear reader and plenty of others, I’m at no shortage of role models to keep me striving to be my best self.
It seemed fitting to have the final say from Adam so asked him for an exclusive comment about something that he has learned about compliance programs as a direct result of publishing a book, here’s what he had to say: ”Writing a book has helped me develop a greater appreciation for the need to let go of ideas or concepts that may have worked in the past or that you really like from a compliance perspective but just aren’t working or advancing the compliance program purpose. Even as I edited my draft before sharing with the publishing team, I realized that I had to let go of some parts of writing (including a whole chapter) that I really liked but just were not consistent with the overall purpose of the book. Letting go of work we have created and feel a sense of pride in can be difficult but something that we have to get comfortable doing if we are to stay focused and committed to our overall purpose of building and running the most effective ethics and compliance programs we can.”
Get your copy of Adam’s book here.
