On Thursday 13th February 2020 the Managing Director of our London office, Viviane Joynes, hosted a webinar entitled ‘Why your Compliance Programme isn’t engaging employees and how to fix it’. She was joined by Nichole Pitts, CEO and Founder of Ethintegrity and Moritz Homann, our Managing Director for Compliance Services, who both shared their insights and expertise. This blog post summarises the content of the webinar.
Why is compliance engagement challenging?
Engaging employees on compliance topics is no easy task. Compliance isn’t seen as sexy. In reality it’s often perceived by employees as boring, abstract and irrelevant. They begrudgingly do their mandatory training and don’t want any further involvement.
While this paints quite a bleak picture, there are some shining examples of companies who have successfully made compliance engaging and more importantly, helped ensure ethical behaviours within their organisation, reducing their overall risk.
Getting engagement right has never been more important especially as regulators globally are increasing the pressure on companies to demonstrate the effectiveness of their compliance programmes.
So where do we start?
Evaluate your organisation
Before putting together an engagement strategy or communication plan, it’s important to understand the compliance culture of your organisation and areas of risk. Three areas should be looked at:
- Undertake or refresh your risk assessment. This will allow you to understand the areas of risk across the organisation that need to be addressed. It may also be worth working with an outside firm or your internal audit team to evaluate your existing compliance programme. Sometimes a programme is implemented but isn’t reviewed or checked. Is it still fit for purpose
- Analyse existing data. Online metrics can shed light on engagement. Look at online traffic for policies and procedures. Look at incoming reports through your whistleblowing channels. Are they increasing/decreasing? What topics are coming up? If you have other data points, see if they provide any insights.
- Understand how embedded ethics and compliance are in your organisation. Do employees know about the compliance programme? Do they know what to do if they become aware of misconduct? Do they feel that their leaders live up to the Code of Conduct? Questions like these can be included in the annual employee survey as well as engaging with the workforce directly and can help identify blind spots and areas of weakness.
Put together a communication plan
Once you have an in-depth understanding of the risks in your organisation and the compliance culture you can then put a communication plan together. This will allow you to be strategic with the roll out of policies and procedures.
Some key points to consider:
- Focus on the purpose of each communication and be clear on the desired result. Is it an action, to create an ethical culture, to implement a policy? What information do you want people to retain? Make sure each communication moves you one step closer to your goal.
- Think about timing and frequency. Use creative messaging at different times of year. For example, before Christmas, Chinese New Year, Diwali when gifts will be given, remind employees what they need to do if they receive or want to give a gift. It’s a balancing act. Ensuring compliance and ethics are front of mind while not creating information overload.
- Make it relevant. Make each message as relevant as possible to the day to day roles of employees and the challenges that they face. Put yourself in their shoes. This will ensure that communications are relevant and engaging.
- Take culture into account. What works in one country may be completely ineffective in others.
- Work with influencers in your organisation. In addition to ensuring ‘tone from the top’, are there key people in specific departments or jurisdictions that have influence and can help effectively deliver your message?
- Make training immersive. Consider facilitation in addition to standard training. Learning tends to be passive with standard training. With facilitation, you create an active learning environment where people are encouraged to problem-solve, run through role-specific scenarios and put themselves in the shoes of the compliance officer. You can use whiteboards, scenarios, games, the options are endless.
- Be innovative, have fun and try new things. Competitions, quizzes, using well known characters to make a point. One example that Nichole referred to was using Marvel movies and the difference in approach between Captain America and Tony Stark, do they have a Code of Conduct? These types of initiatives are effective across cultures and are fun, which makes information retention easier.
Have a toolkit
Put together a diverse set of tools to effectively communicate with different populations. Think about how you can use different media. Sometimes longform, sometimes to provide information in bite-sized chunks.
Your toolkit could include emails, infographics, different types of visuals, newsletters, FAQs. Getting more creative, it could include short videos, podcasts about employees with different roles asking them what their risks are, games, competitions, challenges. It’s surprising how engaged people get when there’s competition and potentially a prize at stake. Most of this can also be done with a very limited budget.
Make compliance easy for employees
When your communications are asking employees to do something, make sure that the steps they need to take are easy and effortless. For example, filling out forms, scanning and sending documents via email will not create compliance superfans. Clicking on a link in an email that takes the employee straight to the relevant policy they need to approve in a few clicks, is a step in the right direction. There’s only so much communication can achieve when processes are inefficient. Try to use technology for a great user experience.
Monitor and measure your efforts
As the communication plan that you’ve put a lot of effort into is being rolled out, what you really want to know is how effective it is.
This is where having a secure online hub where all of your compliance-related data comes together in real-time is invaluable. Yes, you can use spreadsheets to look at your speak up statistics, policy approval and training success rates but this will be cumbersome to put together and then derive trends and red flags from. Digitising the process allows you to track KPIs in real-time, saving on resource and allowing you to spend more time on what you need to do once you’ve established the impact your communication plan is having. From the data, you’ll be able to judge what is and isn’t working and what needs further tweaking.
Understanding your organisation’s ethics and compliance culture and status will allow you to put together an engaging communication plan that is relevant and encourages ethical behaviour, minimising risk within your organisation.
If you found this interesting, why not listen to the free webinar itself which will go into more depth.