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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 1, 2017

Welcome to Day One of 360-degrees of communication in compliance. This month you will learn about techniques that the CCO can use to provide you not only a well-rounded role as a CCO but also facilitate a much more holistic approach to compliance in your organization. Best of all the techniques, discussed are largely available to you at little to no cost. There are things that you can do both in your method of running the CCO positions and innovations that you can bring to the compliance function in your organization. 

A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is about creating a distinctive brand philosophy of compliance which is centered on your consumers. In other words, the customers of your compliance program; I.E., your employees it helps to anticipate all the aspects of your employees needs around compliance especially when compliance is either perceived as new perceived as something that comes out of the home office or is perceived as the Land of No. It gives you the opportunity to build a new brand image for your compliance program. 

Social media is a big part of a 360-degree view so there will be a focus on the use of social media in compliance and how it can facilitate your compliance program through your compliance messaging. I will discuss some specific techniques of social media tactics that have been successfully used by companies. We will consider the culture of compliance and the clash of different cultures that an organization may have, particularly through mergers and acquisitions but also internally, through organic growth and how a 360-degree view can help overcome this. Storytelling and compliance is another mechanism which is facilitated through a 360-degree. 

Other issues to be considered include how can a 360-degree view of communication facilitate your role as a leader in your company and in your compliance program? What are the techniques which can provide a holistic approach to your compliance function? What is the two-way street approach wedded to the benefit of 360-degrees of compliance and communication? Communication is much more powerful when it is a two-way street. Such a view also allows you to information from your customer base, once again your employees back up to your compliance program and incorporate that feedback loop directly into your compliance program going forward. 

There are several concepts which should be included in your 360-degree view of communications in compliance. Begin with an objective so you identify the purpose of your communication and the target of whom you are going to communicate to. Identify as clearly as you can the purpose and reason to ensure your message is aligned with your objectives. For instance, are you implementing a 360-degree view of communication to educate, inform, change perceptions or build trust and commitment? 

Next,  who is your audience? To communicate effectively you need to understand your audience. In any corporation, there are multiple audiences who are the key stakeholders in the 360-degree process. How much do they know? Some of the stakeholders include the Board of Directors, senior management, middle management, employee teams, committees, coaches, facilitators, customers, business partners, vendors, sales agents and representative, strategic alliances and business ventures. What are your distribution channels and how do you track your messaging? You should create a comprehensive spreadsheet to track the messages the intended audience and the delivery mechanism. Another key ingredient of the 360-degree approach is feedback. This is a key component of the 360-degree experience and educate each stakeholder on the benefits of feedback from the 360-degree approach. 

Finally, you need to evaluate what you have done. You can monitor your communication activities by tracking attendance at the events, website statistics, open rate of emails, downloads of materials, video hits; in other words, the same techniques that your marketing folks would use to determine their messaging’s effectiveness. The objective is to build trust for the 360-degree process by determining if the goal achieved. You can utilize surveys or focus groups to assess the impact on your target audience. By focusing on your customer customers of compliance, I.E. your employees, it allows you to identify gaps and improve the communication process for your compliance program. 

Three Key Takeaways 

  1. Remember the definition of 360-degrees of compliance communications. It is an effort that includes the compliance identity into a holistic approach so compliance is in touch and visible to your employees at all times.
  2. What is your objective? What are you trying to do with your 360-degrees view of compliance communications and how are you using that mechanism to deliver the objective your compliance program desires.
  3. Evaluate. You need to evaluate has the message been delivered has it been heard and is it being implemented. 

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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