Editor’s note: Mary Shirley explains what to expect from her conversation session at the Compliance Week 2019 conference titled, Culture of Compliance: Avoiding ‘ViciousCompliance.

As ethics and compliance professionals, it does not take much arm-twisting to convince us that a culture of integrity is important. Like a baby, however, it takes a village to instill a culture of integrity into the DNA of the business. It is not something we can do unilaterally; we need buy-in and commitment from the business.

I will be speaking on a panel addressing the topic of culture at the annual Compliance Week conference. The motivation for my speaking section on the panel is derived from my experience in authoring an article on this very topic. What I found when trying to crowdsource ideas for culture initiatives was that many colleagues in the industry felt content that hosting a compliance fair or compliance week was a good culture initiative. I would respectfully disagree.


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I think hosting a compliance-related outreach and advocacy initiative is awesome—it’s a great indicator that your company is moving away from a check-the-box program and looking at ways in which you can demonstrate that you have a Compliance 2.0 program. My view, however, is that a one-off-type of event, even if it’s for a week, is not repetitive enough to help ingrain ethics in a way that will further the culture.

For example, think about your last compliance week or fair—six months down the track, do you hear of leadership or sales people saying, “I’m going to be very ethical, because after receiving a balloon animal at the Compliance carnival, I know I should act with integrity at all times”?  Let’s face it, that balloon animal and the good feelings it conjured up six months ago are probably not informing the day-to-day decision making of the business. Therefore, I think a fair or dedicated compliance week falls more under a company’s communications campaign rather than substituting for a culture initiative.

The aim of my section is to build on this explanation as to what a culture of integrity initiative is and provide empirical evidence to take back to your businesses to persuade leaders who do not care for “fluffy stuff” that this is something worth investing in—not only for compliance, but also for commercial reasons. 

I don’t want to leave you alone on your quest, so I’ll also be outlining easy-to-implement initiatives that you can introduce to your business immediately to help foster a culture of integrity. If you’re like me, you won’t have access to a bottomless pit of funds, so it’s crucial that these ideas generally be of low to minimal cost. If you’re lucky enough to have more moolah to go around, I’ll also help you spend that by leveling up on these initiatives.

Finally, circling back to the point that we can’t do this alone as a department, I’ll be covering the three people you meet in heaven (heaven being the equivalent of compliance) and addressing three of the most difficult characters you will likely encounter on this journey and the tactics I’ve found most successful for getting them to buy in to the process.

So in summary, I invite you to join me for:

  1. Discussion on the elements required to be a culture of integrity initiative as opposed to a communications initiative
  2. Easy to implement, minimal cost ideas that you can introduce immediately into your own business
  3. Turning your most difficult stakeholders into yaysaysers!

Mary Shirley is senior director of ethics and compliance at Fresenius Medical Care.