Last week I had the privilege of hosting the latest Compliance Week executive forum, this time in Cincinnati to talk about building effective anti-corruption programs. We’ll have a comprehensive look at the discussion there (and at a companion roundtable in Chicago also last week) in an upcoming edition of Compliance Week. Today I want to share some thoughts on a side conversation we had about compliance officers’ other thorny problem: metrics.
After all, you can’t call your compliance program effective—against anti-corruption or anything else—without metrics that tell you whether your training messages are understood and are making a difference. That last part has always been the challenge, because too many metrics give only one fact about compliance: how many calls were placed to the employee hotline, how many training courses were completed, how many indictments were handed down. Those metrics exist in a vacuum. Unto themselves, they give no great insight into the compliance department’s effectiveness, because they don’t say why that metric is the number it is, or whether that number is good or bad. They are metrics that exist in one dimension.
