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Assessing, Improving, and Leveraging
Your Culture of Compliance
Matt Kelly
Editor & CEO
Radical Compliance
Who is this guy again?
Matt Kelly
Editor
Radical Compliance
• Writing, blogging independently at
www.RadicalCompliance.com
• Previously editor of Compliance Week, 2006-
2016
• Do various research, writing projects for
private clients
• I love this stuff!
Order of Events
• Why is a culture of compliance important, and
getting more important?
• What data, relationships, and more do
compliance officers need to understand
culture?
• How can you leverage culture for better
conduct and better investigations?
• Q&A
Part I.
Why Culture of Compliance
Matters
Because Culture Is Everything!
‘Culture isn't just one aspect of the game; it is the
game. In the end, an organization is nothing more
than the collective capacity of its people to create
value.’ — Lou Gerstner
‘Culture eats strategy for breakfast.’— Peter
Drucker
Culture can be about success or disarray — or a mix of both.
Pressures on Culture Today
First are the risks
● More complex business enterprises
○ Globalized reach
○ Third parties
● More economic uncertainty
● More ‘tightly coupled’ systems
More forces tugging at that ‘collective capacity’ to advance
objectives.
Pressures on Culture Today
Second are the demands
● Highly regulated business landscape
● Stronger penalties for wrongdoing
● More ‘shaming’ of corporate conduct
on social media, elsewhere
● Stakeholders just want a better, more
ethical performance from corporations
Employees do want to help!
Source: Ethisphere, 2019
So what are the obstacles here?
● Fear of retaliation
● Belief that no corrective actions will
happen
● Confusion about what employees are
supposed to do
● Conflicting messages from leadership
Part II.
What Do You Need
to Understand Culture?
Data, as much as you can get
● Issues reported on internal hotline,
categorized in many ways:
○ Issue itself
○ Location
○ Level of employees
● Issues specifically around retaliation
● Case closure times, bottlenecks
number of responses
Look beyond compliance data, too
● HR data
○ Employee turnover
○ Exit interviews
○ D&I trends
○ Employee sentiment surveys
● Don’t forget external sources
○ Blind, Glassdoor.com
○ Social media
Precision in data and reporting
● You are looking for root causes:
○ Bad leaders?
○ Bad policy?
○ Bad processes?
● Looking for deviations from norm
○ Culture vs. sub-culture
Anticipate the data challenges
● Finding it in the first place
● Completeness, accuracy
● Consolidating all data for holistic view
● Slicing & dicing for precise analysis
What tools and analytics do you need, and what relationships do
you need, to make all this work?
Part III.
Leveraging Culture
to Improve Conduct
and Investigations
Begins with the Code of Conduct
● Write it down!
● Keep it simple!
● Stress company’s ethical values
● Stress the priority of ethics
Employ a strategy
● The message: ‘A culture of compliance is
good for business’
● Who are allies to deliver that message?
● How do you incentivize the behavior?
● What tools do you leverage?
● How do you monitor progress?
Work with the workforce
● Policy development
● Internal reporting
● Investigations
● Training
Develop an OODA loop
● Observe: What is the raw information?
● Orient: How do I interpret that?
● Decide: What action do I take?
● Act: Do it.
The faster you cycle through the loop, the more
responsive you are to changing conditions.
Observe
Orient
Decide
Act
Questions?
Find more free webinars:
www.i-sight.com/resources/webinars
@isightsoftware
Contact
Matt Kelly
Contact
i-Sight
webinars@i-sight.com
mkelly@radicalcompliance.com
www.RadicalCompliance.com
www.linkedin.com/in/mkellycompliance

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How to Assess, Level Up, and Leverage Your Culture of Compliance

  • 1. Assessing, Improving, and Leveraging Your Culture of Compliance Matt Kelly Editor & CEO Radical Compliance
  • 2. Who is this guy again? Matt Kelly Editor Radical Compliance • Writing, blogging independently at www.RadicalCompliance.com • Previously editor of Compliance Week, 2006- 2016 • Do various research, writing projects for private clients • I love this stuff!
  • 3. Order of Events • Why is a culture of compliance important, and getting more important? • What data, relationships, and more do compliance officers need to understand culture? • How can you leverage culture for better conduct and better investigations? • Q&A
  • 4. Part I. Why Culture of Compliance Matters
  • 5. Because Culture Is Everything! ‘Culture isn't just one aspect of the game; it is the game. In the end, an organization is nothing more than the collective capacity of its people to create value.’ — Lou Gerstner ‘Culture eats strategy for breakfast.’— Peter Drucker Culture can be about success or disarray — or a mix of both.
  • 6. Pressures on Culture Today First are the risks ● More complex business enterprises ○ Globalized reach ○ Third parties ● More economic uncertainty ● More ‘tightly coupled’ systems More forces tugging at that ‘collective capacity’ to advance objectives.
  • 7. Pressures on Culture Today Second are the demands ● Highly regulated business landscape ● Stronger penalties for wrongdoing ● More ‘shaming’ of corporate conduct on social media, elsewhere ● Stakeholders just want a better, more ethical performance from corporations
  • 8. Employees do want to help! Source: Ethisphere, 2019
  • 9. So what are the obstacles here? ● Fear of retaliation ● Belief that no corrective actions will happen ● Confusion about what employees are supposed to do ● Conflicting messages from leadership
  • 10. Part II. What Do You Need to Understand Culture?
  • 11. Data, as much as you can get ● Issues reported on internal hotline, categorized in many ways: ○ Issue itself ○ Location ○ Level of employees ● Issues specifically around retaliation ● Case closure times, bottlenecks number of responses
  • 12. Look beyond compliance data, too ● HR data ○ Employee turnover ○ Exit interviews ○ D&I trends ○ Employee sentiment surveys ● Don’t forget external sources ○ Blind, Glassdoor.com ○ Social media
  • 13. Precision in data and reporting ● You are looking for root causes: ○ Bad leaders? ○ Bad policy? ○ Bad processes? ● Looking for deviations from norm ○ Culture vs. sub-culture
  • 14. Anticipate the data challenges ● Finding it in the first place ● Completeness, accuracy ● Consolidating all data for holistic view ● Slicing & dicing for precise analysis What tools and analytics do you need, and what relationships do you need, to make all this work?
  • 15. Part III. Leveraging Culture to Improve Conduct and Investigations
  • 16. Begins with the Code of Conduct ● Write it down! ● Keep it simple! ● Stress company’s ethical values ● Stress the priority of ethics
  • 17. Employ a strategy ● The message: ‘A culture of compliance is good for business’ ● Who are allies to deliver that message? ● How do you incentivize the behavior? ● What tools do you leverage? ● How do you monitor progress?
  • 18. Work with the workforce ● Policy development ● Internal reporting ● Investigations ● Training
  • 19. Develop an OODA loop ● Observe: What is the raw information? ● Orient: How do I interpret that? ● Decide: What action do I take? ● Act: Do it. The faster you cycle through the loop, the more responsive you are to changing conditions. Observe Orient Decide Act
  • 21. Find more free webinars: www.i-sight.com/resources/webinars @isightsoftware Contact Matt Kelly Contact i-Sight webinars@i-sight.com mkelly@radicalcompliance.com www.RadicalCompliance.com www.linkedin.com/in/mkellycompliance