What does it take to build a successful ethics and compliance program? If the topics in a September 2017 Society of Corporate Compliance and Ethics (SCCE) webinar are an indicator, it takes attention to the following four major areas:
- Obtaining commitment for a program from the senior leadership and the board
- Assessing risks and gaps, and implementing elements and controls in an ordered way
- Leveraging compliance partners and champions
- Measuring, monitoring, and improving the program
Vin Lacovara, Compliance and Privacy Officer for Catholic University of America (and the presenter for the September 2017 webinar) expanded on those four areas in another presentation earlier this year, part of SCCE’s June 2017 Higher Education Conference (Duggan, Lacovara, and Williams, 2017).
As expanded, those four areas become seven:
- Assess existing elements, missing elements, partners and champions, culture, and risks
- Define strategies, policies, and controls, to include review of missing policies, helplines (hotlines) and investigative processes, compliance training, and risk assessments
- Implement those strategies, policies, and controls
- Communicate and train on those strategies, policies, and controls, to include identifying common and high risks as well as people who can help
- Measure, monitor, and improve, using regulatory risk assessments, targeted compliance assessments, and metrics
- Report to senior staff and board
The importance of obtaining commitment from the top can’t be overstated. Such commitment is best gained and sustained by making a strong business case and by tightly linking ethics and compliance processes to other existing processes wherever possible.
As outlined in a 2010 SCCE Compliance & Ethics Institute presentation, one can make a strong business case by setting the right expectations, providing a model plan that is scalable and reasonable, highlighting benefits and positive outcomes, communicating requirements and needs, effectively addressing resistance and challenges, and maintaining ongoing communication and engagement (Essrig, Triguba, and Lunday, 2010, slide 7).
A strong business case can be made, according to the presenters, by presenting a strategic vision that reflects the value proposition for the organization and includes desired outcomes and benefits, by assuring the proposed strategic plan aligns with the short and long-term vison and objectives of the leadership team and organization, and by taking such steps as aligning and integrating compliance risk approaches with other programs that address operational, financial, and compliance risks (see presentation slides 16-17).
For even more information about how to build successful programs, see our blog post about the Ethics and Compliance Initiative’s report Principles and Practices of High-Quality Ethics & Compliance Programs.
Ethical Advocate works with ethics and compliance officers on ethics hotline implementation and management, training, and related ethics and compliance issues. We welcome your questions.
Duggan, Vicki, Vin Lacovara, and Julian Williams. “Building and Managing Successful Compliance and Ethics Programs—A Tale of Three Institutions,” May 2017, pages 5-8. http://www.corporatecompliance.org/Portals/1/PDF/Resources/past_handouts/Higher_Ed/2017/V1__ses_W2_2slides.pdf
Essrig, C. Lee, Greg Triguba, and Jason Lunday. “Building an Effective Compliance and Ethics Program: Challenges & Strategies,” 2010. http://www.corporatecompliance.org/Portals/1/PDF/Resources/past_handouts/CEI/2010/P2_BuildinganEffectiveComplianceandEthicsProgramChallengesandStrategies.pdf
SCCE. “Building a Successful Compliance and Ethics Program,” (webinar brochure). http://www.corporatecompliance.org/Portals/1/PDF/events/Brochures/170925_SCCE_Building-a-Successful-Compliance-Ethics-Program.pdf