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FCPA Compliance Report

Tom Fox has practiced law in Houston for 30 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.
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Nov 6, 2017

I am a huge fan of using social media in your compliance function. But how can you get your arms around how to structure such a program for their company? In an article in the MIT Sloan Management Review, entitled “Finding the Right Role for Social Media in Innovation”, Deborah Roberts and Frank Pillar reviewed companies that were not deriving significant benefit from their customer facing social media efforts. I found their discussion of potential remedies as a useful tool to help CCOs design an internal company wide social media campaign. 

After acknowledging that social media focuses on the social aspects of the communication, the most important thing to remember is that communication in social media is two-way; both inbound and outbound. It helps to bring your employee base together in an efficient manner to create an environment conducive to compliance for your organization. It also has the benefit of continued engagement. It is more than putting on training or even a Compliance Week set of initiatives, you can continue the conversation and enthusiasm about compliance going forward throughout the year. 

The authors break this down further into three parts that emphasize (1) the need to listen to and learn from user-generated content; (2) the need to engage and facilitate dialogue with employee innovators; and (3) to find an audience of early adopters to create excitement and collect feedback. 

Listen First 

This is the method the authors suggest of how to generate employee insights into your compliance program “where activities are designed to extend the breadth and depth of how organizations search for innovations” even in the compliance arena. The key is that the compliance function must be listening and listening in a manner which they may not have used previously. You will need to “learn to read the signals from large, diverse, disconnected, and unstructured pools of data generated by users. In addition, they will learn to analyze and convert blog posts, tweets, and user-generated content into valuable insights for new products.” 

Compliance professionals will need the skills of both a social scientist and a data scientist. This is because compliance practitioners will need to “assimilate, combine, and utilize data from many different sources” across the globe as compliance practitioners need “to acquire skills in computational techniques to unveil trends and patterns within and between the various data sets.” The overall goal “is to sharpen their business acumen and teach them how to communicate the findings to those involved in [compliance] projects.” 

Engage and Facilitate a Discussion 

The next step is companies understand is to actively engage and involve employees in the innovation process around compliance. The overall goal is to be more collaborative to allow employees to be more involved in the design process. As a CCO or compliance professional you will learn how to engage, find, and pick the right participants, then develop the right incentives to encourage participation. Creativity is both an input and an output of the process. Managers must also develop skills in relationship building and gain experience in the art of conversation and dialogue, which is a key aspect of any collaboration. Managers must learn how to become better facilitators and community managers. 

One of the important factors is to visit with “unconventional users” to help facilitate the creative process. Here social media itself can be a powerful tool, facilitating a two-way communication street to allow the compliance function to hear and even see what business and other types in the field may see and hear. The model of involving employees for in-house innovation has always been useful to help build buy-in and acceptance but the authors also found that more diverse participation in the creation process can provide a richer developed process. 

Collect Feedback 

Social media facilitates a two-way street of communication. Social media can also afford the compliance function the opportunity to interact more directly with its customer base, the company’s employees, in a manner that is far more engaging than the old command and control approach. 

If your goal in the compliance function is to create awareness and publicize your compliance program and initiatives, social media can be a powerful tool for you. This is so paramount it should become a core activity of your compliance function. Using social media tools, your compliance function can not only tell the story of compliance but also communicate expectations and even train. Yet once again it is simply more than a one-way tool as using social media facilitates a two-way communication. Just as employees are more apt to tell you about a concern immediately or soon after they have been trained on that issue; they may well communicate directly with you after having received a social media communication on subjects such as managing of third party relationships. 

CCOs and compliance practitioners need to develop a dedicated compliance strategy around social media, in the context of your corporate objectives. It allows you a 360-degree view of compliance, through which you can take the input from your employee base and create a compliance experience that your employees will embrace. 

Three Key Takeaways

  1. Never forget that social media is a two-way communication.
  2. Company employees are the customers of the compliance department.
  3. As with all compliance issues, assess what works for your company and tailor your social media approach appropriately.

This month’s podcast series is sponsored by Dun & Bradstreet.  Dun & Bradstreet’s compliance solutions provide comprehensive due diligence reporting and analysis to reduce your risk of working with fraudulent companies by accessing a company’s beneficial ownership, reputation risk and more.  For more information, go to dnb.com/compliance.

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