Being the "Necessary Evil" is so 2016: It’s Time for Ethics & Compliance to Rebrand Itself

As part of our culture assessments, NAVEX Global’s Advisory Services team has led more than 1,300 in-person focus groups with employees at all levels, in many countries and from every industry. We’ve heard candid comments about what employees really think about their organization’s E&C program, and the personnel who run it.

Unfortunately, in many organizations, the E&C department is viewed as “the people who say no.” By this, employees mean that E&C is viewed as enforcers of rules or “policy wonks.” E&C is seen as not aligned with the organization’s business goals but instead is a “necessary evil,” a “CYA” function.

Rebranding your office as a positive contributor to the business and a key part of the management team may be a long-term goal, but moving in that direction will pay immediate dividends.

Key Steps for Organizations to Take:

1. Examine the Root Cause of Employee Opinions

If your E&C department is viewed as the “people who say no,” (and it probably is) your first step should be to determine the specific causes of this attitude. In many cases, the damage is self-inflicted and can be quickly corrected. Focus groups, interviews or informal discussions are all good ways to get to the bottom of the matter, and these steps themselves may help signal that your office is trying to change.

The consequence is that the E&C office becomes wholly defined by its emails and policies, which can contribute to the negative image.

Some organizations have found that the root cause of the problem are what employees see as onerous or irrelevant requests from your office including overly complicated annual certification, complex and impractical gift registries, or conflict disclosure processes; lengthy training that seems repetitive or not targeted to their actual responsibilities; and perhaps most often, lack of accessibility. In too many cases E&C officers are viewed as removed or impersonal. The consequence is that the E&C office becomes wholly defined by its emails and policies, which can contribute to the negative image. Remember that at its roots, ethics and corporate culture are personal and interpersonal matters. For this reason, direct access and “face time” can go a long way toward improving your brand.

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2. Be Transparent and Respect the Employees’ Time
From an employee’s point of view, E&C requirements that seem irrelevant or consume an inordinate amount of time are seen as clear evidence that the E&C office doesn’t “get it,” which fuels the conclusion that E&C is marginal to the business and not aligned with business imperatives. In the coming year, if you do nothing else to address your E&C brand, vow to be more respectful of employees’ valuable time, and be sure to include explanations of why the training or other E&C asks are needed. Develop a multiyear E&C communications and training plan that will ensure its relevancy and help you target your training and communications to specific roles and responsibilities. And remember: short and simple is always best.

3. Reposition the E&C Office as a Strategic Management Ally
Meet with key managers and ask them how your office can help them meet their goals and solicit their suggestions on ways to collaborate and improve efficiency and effectiveness. Focus discussions on risk identification and management strategy. Talk less about the byzantine U.S. Sentencing Guidelines and other arcane requirements and more about operational effectiveness. Be practical, helpful and engaged. Act more like a strategic partner and less like a “compliance cop.”

4. Don’t Neglect Your Third Parties
Risk identification and mitigation efforts should also include outreach to third parties. Positioning your office as a resource for third parties will not only change how you’re perceived, but it can also go a long way toward improving supply chain compliance.

Read More: Third-Party Risk Programs Should Focus on Offense, not Defense

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