What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/customers are your employees. Social media presents some excellent mechanisms to communicate the message of compliance. Many of the applications we use in our personal communication are free or available at very low cost. So why not use those same tools in your internal compliance marketing efforts? Here are three key messages to get across …
Letting your employees know what you stand for. In the 2012 FCPA Guidance, the Justice Department and Securities and Exchange Commission said that the basis of any anti-corruption compliance program is the code of conduct, as it is “often the foundation upon which an effective compliance program is built. As the Justice Department has repeatedly noted in its charging documents, the most effective codes are clear, concise, and accessible to all employees and to those conducting business on the company’s behalf.” Promote your code of conduct as your standard of expectations.
Celebrating their efforts. Celebrate means a more public display of success. Financial rewards may be given in private, such as a portion of an employee’s discretionary bonus credited to doing business ethically and in compliance. While it is true that those employees promoted for doing business ethically are very visible and are public displays of an effective compliance program, a company can take this concept even further through a celebration to acknowledge the culture of compliance for its day-to-day operations.
Giving your employees a way to raise their hands. Companies should give employees a clear, simple, and concise mechanism to ask for help and report concerns. The 2012 FCPA Guidance states, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation.” Make sure you employees know how, where and to whom they can ask for help.