A new year is always about new possibilities and fresh starts. If you are reading this because you are new to the field, welcome from those of us who are a bit longer in the tooth – we are excited for you and want to help you create an enthusiasm for your work that is contagious. And if you are one of the tenured professionals, welcome back to a new year – we are excited for you too, the field is ever reinventing itself.
So let’s think about what has not changed from last year to this:
- The U.S. Sentencing Guidelines still provide credit to corporate miscreants for strong compliance programs.
- There are always going to be some miscreants.
- A strong compliance program can help your corporate leaders sleep at night knowing the likelihood is greater that those miscreants will be found before doing too much damage.
What are a the keys to a strong compliance program? I have a few favorites.
- Not just strong “tone at the top” but real, visible buy-in. What does this look like? Authentic communication around values, swift action in the face of wrongdoing, and probing questions about the program.
- Cross-departmental committees that share compliance information.
- Quarterly reports to the board or a board committee on compliance program details.
- A yearly communication plan that is timed with other corporate messaging.
- Metrics that are meaningful. Don’t just count your hotline calls. Consider what people are asking, from which departments are the most questions coming, and is there a trend or a story line emerging?
- A captive audience. Go live with your colleagues when you are able and talk about why you care about compliance, and why they should care too.
These are just a few thoughts to start the year. I hope you are deep into your planning cycle and ready to start thinking about first quarter progress. Don’t be afraid to embrace your role in compliance; after all, someone appointed you to the role knowing you have the talent to make good things happen. Let your head embrace the intellectual challenge of compliance lingo and metrics. And let your heart embrace the good you are doing for your company, colleagues, owners, shareholders, and all.
This alert was written by Jane Lewis-Raymond when she was a partner at the firm.