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How Behavioral Psychology Can Help
in Gaining Compliance
Influencing People to Do the Right Thing
Virginia MacSuibhne, JD, CCEP
Chief Compliance Officer, Roche Molecular Systems, Inc.
Virginia MacSuibhne, JD, CCEP
Virginia MacSuibhne is the Chief Compliance Officer for Roche
Molecular Systems, Inc. where she is responsible for managing
and directing all aspects of the organization's ethics and
compliance program and related infrastructure. She is
experienced in records and information management programs,
investigative processes and management, and ethics and
compliance risk assessment and management activities.
Virginia is a member of the California Bar, Society for Human
Resource Management, Society of Corporate Compliance &
Ethics, Bay Area Ethics and Compliance Association, and the
American National Standards Institute Committee developing
the National Standard for Workplace Violence Prevention.
2
Lessons from Psychology
Communication: content and delivery matter
3
INCREASING POSITIVE RESPONSES
WITH COMMUNICATION TOOLS
4
Get Introduced
An introduction by another person can
increase your ratings
5
Use Sticky Notes
Handwritten sticky notes can increase
response rate
6
Handwritten Thank You
Adding a handwritten “thank you” can
further increase response rate
7
TELL PEOPLE WHY
”BECAUSE”
Increases chances of cooperation
8
MAKE IT EASY
9
Rhyme Time
10
Memory Aids
Can increase compliance when
properly placed
11
Use Mirrors & Eyes
Mirrors and eyes can increase socially
desirable behavior
12
INCREASING POSITIVE RESPONSES
BY FRAMING FOR COMPLIANCE
13
Get Active Public Commitment
14
Writing or other active involvement has
a positive impact on compliance
Use Numbers
Publishing compliance numbers/
percentages can increase like action
15
Tell People What To Do
16
Give Happy Feedback
Increase response or compliance
17
When Using Fear… Offer Specifics
to Counter
When using fear to activate people, offer
specific ways to counter the threat
18
Frame As Incomplete
People are natural builders, motivated
to help complete projects
19
Rare, Unique Items
People are collectors and they like rare items
20
Free Gifts And Services
21
HANDLING DRAWBACKS, FAILURES
AND ERRORS AND OTHER
CONSIDERATIONS
22
Mention Drawbacks
MENTIONING DRAWBACKS CAN
CREATE PERCEPTION OF HONESTY
23
Offer Error-based Training
24
Explain Failures Early
25
Timing Matters
26
Beware Ecommunications
Emails can be misunderstood and
diffuse responsibility
27
Know Your Audience
Global differences exist
28
Summary
• Get introduced
• Use sticky notes
• Add a handwritten thank you
• Use the word “because”
• Make it easy (to read, and say)
• Rhyme it
• Place message where activity is
• Use mirrors, eyes and names
29
Summary
• Get active, public commitment
• Give percentages to encourage action
• Tell people what to do or not do
• Give a smiley face or a gold star
• When using fear, offer a specific way to counter threat
• Frame as incomplete to enlist builders
• Offer rare, unique items
• Give it away
30
Summary
• Mention drawbacks
• Use error based training
• Admit mistakes
• Notice the time
• Beware email
• Know your audience
31
Reference Materials
Yes! 50 secrets from the Science of Persuasion by N.
Goldstein, S. Martin and R. Cialdini
Influence The Psychology of Persuasion by. R Cialdini
Methods of Persuasion by N. Kolenda
The Art of Thinking Clearly by R. Dobelli
Nudge by R. Thaler and C. Sunstein
Made to Stick by C & D Heath
32
Thank-you for participating
If you have any questions, please feel free to email
them to:
Virginia MacSuibhne, JD, CCEP
Chief Compliance Officer, Roche Molecular Systems, Inc.
virginia.macsuibhne@roche.com
Please Connect With Me On LinkedIn!
Joe Gerard, Vice President Marketing and Sales. i-Sight
j.gerard@i-sight.com

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How Behavioral Psychology Can Help in Gaining Compliance

Editor's Notes

  1. Compliance is about getting employees to do the right thing at work…behavioral psychology studies show that there are some particular tools and techniques that can be used to influence certain behavior Communication matters – more than ever - 2012 DOJ and SEC declined to prosecute Morgan Stanley in an FCPA case largely on the basis of its internal controls AND communications… Stickiness Communication is a cornerstone of effective compliance programs Not just what we communicate that matters, but also HOW we communicate There are many techniques and tools (most used by marketers and salespeople to encourage buying behavior) that Compliance and Ethics professionals can and should leverage in communicating their messages to encourage people to act in a compliance manner Certain techniques and tools can increase positive responses or compliance Certain messaging on failures, drawbacks & errors are also more successful Psychology (and history) also have some key lessons in how to handle failures of compliance, errors and other issues How to get people to do what you want Like compliance, persuasion is an art, not a science
  2. Get someone else to speak on your behalf (even if they are paid to do so) and participants rate you more favorably on nearly every scale…even/especially likability…when you are introduced by someone else versus your own introduction you need not even be connected to that person…e.g. receptionist says “oh, you need to speak with Pratima or Sri or [insert name]” What meetings are you attending and how can you ensure that another person introduces you to the group? Make sure they use your name (you don’t want to be known as “compliance”
  3. Cover letter and survey (no handwritten message) Handwritten message on cover letter itself Handwritten sticky attached to survey cover letter 75% response rate Consider when distributing info to Leaders or others actually sending a hard copy with handwritten sticky note, same for Code of Conduct – send to employees with handwritten sticky note
  4. Cover letter and survey (no handwritten message) Handwritten message on cover letter itself Handwritten sticky attached to survey cover letter 75% response rate
  5. Ellen Langer of Harvard Psych and the Xerox experiment TAKEAWAY: Accompany requests with a strong rationale (even when the reason might be clear).
  6. Get rid of the “lawyer language”
  7. Allows the information to be more easily processed and judged as more accurate Recall increases Think pneumonics COMPLIANCE not DEFIANCE
  8. TAKEAWAY: Integrate brand components at the place where action occurs Energizer Bunny was a character people recalled but they did not recall the company it was associated with = the advertising campaign needed to integrate the essential pieces in the store product displays and packaging E.g. student drinking campaign = 65% students have less than 3 drinks at a party ---put the message in places where the drinking occurs e.g. coasters or other items people would take to party versus posters
  9. It’s like someone’s watching – Open seating areas Also, we like to think of ourselves as good people who do the right thing – we see ourselves or identify ourselves by name – it encourages us to Most people come to work wanting to do the right thing TAKEAWAY: Ask names, use name tags, use mirrors & eyes in program designs.
  10. Active commitment vs. passive commitment – when active it more than doubles the action…e.g. have clients Writing things down has more positive impact on goal achievement Those who agree in some active way (completing a form, filling out appointment card themselves) are more likely to act as they promised Still have people sign the code of conduct agreement – online clicks not yet known if they have same positive effect Sign posters Come to front of room to sign in Ask potential voters to predict whether they will vote and have them provide a reason for their prediction Publicly state commitment – “we’ll mark you down as a yes and let others know” “Please call to cancel” vs. “Will you please call if you have to cancel?” fill out their reminder cards = active
  11. Create the bandwagon effect – social proof e.g. What happens when hotel guests learned the majority of others had participated in towel reuse Hotel study
  12. Telling people what bad behavior is happening can increase that bad behavior e.g. National Park Management messaging - THEFT IS OCCURRING saw an increase in theft – they told people it was disappearing so people wanted to get theirs before it was gone - NO SIGN – less theft than with theft sign or - NO STEALING – got right behavior
  13. EFFECT OF ADDING SMILEY FACE TO ENERGY CONSUMPTION REPORTS SHOWING HOW YOU RELATE TO OTHERS emojis
  14. E.g. when want people to know about risks and need for flu shot, provide info about how/where to get the shot
  15. People like to build and like to see things done When ask others to help point out how the person has already taken steps toward completion Make it a puzzle –people want to solve
  16. TAKEAWAY: Focus on what is unique about your company or program and offer “exclusives” and new items annually in series. Rare and unique items are perceived as more valuable (e.g. misdated souvenirs) – we want things of limited quantity or available for a limited time and feel they have more value - what is rare and unique about your program - “exclusive” - Disney movie vault But be aware of loss aversion – we are more interested in not losing something than in getting something new – e.g. new coke created more loss aversions
  17. People love something free – especially when it’s unexpected and when they get something free they feel compelled to reciprocate We like to take leftover t-shirts and mugs and pens from product launches of years ago and give them as prizes during corporate compliance week
  18. Early mention of small drawbacks can create a perception of honesty, especially when paired with the silver lininge.g. “small but cozy” restaurant L’oreal “expensive but worth it” Avis “we’re number two but we try harder” Higher price offset by longer lasting “Compliance isn’t always easy, but it’s the right thing to do”
  19. TAKEAWAY: Create training with real errors. Creates greater improvements in judgment How have others made errors in the past How to avoid those errors
  20. TAKEAWAY: When bad things happen come clear early and take responsibility. “strategic decisions” vs “unexpected economic downturn” If problem is from technical difficulties present and make clear more control will be exerted in the future Attributing failures to internal causes can result in increased public perception and increased profits Annual Report Framing
  21. TAKEAWAY: When stakes are high, reduce multi tasking and make important decisions when most awake When tired, people are more susceptible to deceptive influence of others Same for distraction Expense reports just after coffee? How to create “just in time” – when people are about to leave for China or high risk location – can you require training just then instead of at hiring?
  22. Can be ignored Can be misunderstood Can diffuse responsibility E.g. multiple bystanders to crime decreases the chances that anyone will respond – Kitty Genovese 5 or more bystanders decreased response by over 30% TAKEAWAY: Engage in multiple methods of communication, especially when call to action.
  23. Can be ignored Can be misunderstood Can diffuse responsibility E.g. multiple bystanders to crime decreases the chances that anyone will respond – Kitty Genovese 5 or more bystanders decreased response by over 30% TAKEAWAY: Engage in multiple methods of communication, especially when call to action.