“Hotline turf war: Compliance or HR’s territory?” This is the intriguing title of a recent article in the online version of Workforce magazine.
As stated in the article, the recipe for an effective compliance program includes training for all employees, an anonymous hotline, and attestation to a code of ethics. It also involves the less-well-defined area of “organizational culture” (Pastin, 2015).
The compliance function in an organization, be it a department or an officer, is typically responsible for the overall compliance effort, although clearly aspects of such an effort, notably culture and training, fall within the bailiwick and expertise of the human resources (HR) function. Too often, the two functions do not play well together.
According to this article, the antipathy between the two functions starts with the handling of hotline calls, which often concern HR-related issues. The compliance function (understandably) wants to retain responsibility for investigating all reported concerns. HR, presumably, would prefer to field HR-related topics, and it should be brought into the loop more often than it is.
Whatever the source of friction, it is in the best interests of both compliance and HR, and of the entire organization, for the two functions to improve their working relationship. Three strategies are suggested.
Work together on compliance training
According to Mark Pastin, the author, compliance professionals often have backgrounds in audit, law, or law enforcement and tend to focus required training efforts on compliance with the law and the rules (and the dire consequences of failing to comply). HR professionals are more likely to have the background and expertise to develop more broadly focused training efforts intended to build organizational culture, to include compliance.
Corporate compliance will make more sense to employees, says Pastin, when presented as part of overall organizational culture and purpose.
Cooperate on hotline calls
A key goal of hotlines, according to Pastin, is to encourage employees to report concerns internally rather than externally. He also states that the number of hotline calls per year in large organizations is equal to about three percent of the total number of employees, and that the majority of the calls address HR issues.
HR professionals are used to working through issues with employees internally, a benefit to the process. If they are invited to investigate calls related to HR issues, they can also lift a burden from compliance professionals, who can then focus on the calls related to fraud and other compliance violations.
Create a positive code of ethics
Many organizations, perhaps most, have some form of a code of ethics. Every year, employees are typically required to attest that they have received and will read the code of ethics. One problem, as identified in the article, is that many codes of ethics are long and filled with jargon and legalese. If HR and compliance professionals collaborated on developing or modifying the code, each group could catch the other’s jargon and together both could create a document that employees would be likely to read, understand, and remember.
It’s time to remove barriers created by a mindset of “compliance’s territory” vs. “HR’s territory.” It will be a win-win for the entire organization.
Ethical Advocate provides comprehensive ethics and compliance solutions, including ethics and compliance training and confidential and anonymous hotlines. Contact us for more information.
Pastin, Mark. ‘Hotline Turf War; Compliance or HR’s Territory?” Workforce, November 24, 2015. http://www.workforce.com/articles/21751-hotline-turf-war-compliance-or-hrs-territory