One thing that must be continuously emphasized is that compliance is a business process—and as a business process, the greater the operational excellence, the more efficient a company is and, at the end of the day, the more profitable. It is this execution of the business process, not the implementation of a paper, check-the-box exercise, that is critical to performance.
Borrowing from the world of worker safety, there are three key steps for compliance operational excellence. The first is that one must recognize that doing business in compliance evidences more efficient business structure and process in an organization. Compliance internal controls are largely financial internal controls, which means that the more efficiently your internal controls function runs, the more efficiently your company will run.
The second is that the strength of the company’s products and services can be used to emphasize operational excellence in compliance. Companies that are required to pay bribes to garner business do so because they cannot compete on a level playing field. Simply put, they have to cheat to get business because their products and services are inferior. Operational excellence should be used to help sell, not cheat.
Finally, compliance excellence never depends on just the CEO or even the CCO alone. It is a company-wide effort that starts with a solid foundation and business dedication to ethical business practices. A best practices compliance program should be implemented, all key stakeholders must be trained, and there should ongoing monitoring of the business processes of compliance.
Compliance is a dynamic process because business is a dynamic process. Moreover, it is a collaborative process that works up and down the chain at any organization, literally from the boardroom to the shop floor. By focusing on the business process nature of compliance, you can create a more effective compliance regime.