Social Media III. TwitterI continue my exploration of the use of social media in your Foreign Corrupt Practices Act (FCPA) compliance program today. One of the ways that Chief Compliance Officers (CCOs) and compliance practitioners can communicate about their compliance programs is through the use of the social media tool Twitter. In an article in the Summer issue of the MIT Sloan Management Review, entitled “How Twitter Users Can Generate Better Ideas”, authors Salvatore Parise, Eoin Whelan and Steve Todd postulated that “New research suggests that employees with a diverse Twitter network – one that exposes them to people and ideas they don’t already know – tend to generate better ideas.” Their research led them to three interesting findings: (1) “Overall, employees who used Twitter had better ideas than those who didn’t.”; (2) In particular, there was a link between the amount of diversity in employees’ “Twitter networks and the quality of their ideas.”; and (3) Twitter users who combined idea scouting and idea connecting were the most innovative.

I do not think the first point is too controversial or even insightful as it simply confirms that persons who tend have greater curiosity tend to be more innovative. The logic is fairly straightforward, as the authors note, “Good ideas emerge when new information received is combined with what a person already knows.” In today’s digitally connected world, the amount of information in almost any area is significant. What the authors were able to conclude is that through the use of Twitter, “the potential for accessing a divergent set of ideas is greater.”

However it was the third finding that I thought could positively impact the compliance profession, the role of the Idea Scout and the Idea Connector. An idea scout isan employee who looks outside the organization to bring in new ideas. An idea connector, meanwhile, is someone who can assimilate the external ideas and find opportunities within the organization to implement these new concepts.” For the compliance practitioner, the ability to “identify, assimilate and exploit new [compliance] ideas” is the key takeaway. However to improve your compliance innovation, “you need to maintain a diverse network while also developing your assimilation and exploitation skills.”

For the compliance practitioner, Twitter can be “described as a ‘gateway to solution options’ and a way to obtain different perspectives and to challenge one’s current thinking.” Interestingly the authors found that “It’s not the number of people you follow on Twitter that matters; it’s the diversity within your Twitter network.” The authors go on to state, “Diversity of employee’s Twitter network is conductive to innovation.” Typically an Idea Scout will “identify external ideas from experts and resources on Twitter.” Clearly the compliance practitioner can take advantage of experts with the anti-corruption compliance field but there is perhaps an equally rich source of innovation from those outside this arena.

An interesting approach was what the authors called the “breadcrumb” approach to finding innovation leaders and thought-provokers. It entailed a “period of “listening” to colleagues and industry leaders who are on the platform – including what they are tweeting about, who they are following and replying to on the platform, who is being retweeted often”. So with most good leadership techniques the first key is to listen.

Equally important to this Idea Scout is the Idea Connector, who is putting the disparate strands from Twitter’s 140 character tweets together. For the compliance function, this will be someone who identifies compliance best practices or other information from Twitter ideas, can then put them together and direct the information to the relevant company stakeholders. Finally, such a person can “Curate Twitter ideas and matches them with company resources needed to implement them.”

Here the authors listed a variety of ways an Idea Connector can use Twitter. One user said, “I try to sift through all the Twitter content from my network and look for trends and relationships between topics. I put my analysis and interpretation on it. I feel that’s where my value-add is.” Another method is to focus on analytics and one user “filtered specific subsets of the topic for different stakeholders” at his company. Another method was to create “social dashboards or company blogs based on the insight” received thought Twitter. Interesting, one of the key requirements for successfully mining Twitter was in finding ways to share its content “since many employees, especially baby-boomers don’t use the platform themselves.” Conversely by mining information from Twitter and presenting it, this can allow these ‘technologically challenged’ older employees to ascertain how they can target millennial’s.

But as much as these concepts can move a CCO or compliance practitioner to innovation in a compliance program, it can also foster additional information through the following of your own employees. It is well known that Twitter can facilitate greater communication to and between the compliance function and its customer base, aka the company employees. However the authors also point to the use of Twitter to enable this same type of innovation because it “is different than email and other forms of information sources in that it enables continuous engagement”.

Twitter was created to allow people to connect with one and other and communicate about their activities. However the marketing potential was immediately seen and used by many companies. Now a deeper understanding of its use and benefits has developed. For the compliance practitioner one thing you want to consider is to align your Twitter and great social media strategy with your compliance strategy; match your Twitter strategy to your compliance strategy.

Twitter can be powerful tool for the compliance practitioner. It is one of the only tools that can work both inbound for you to obtain information and insight and in an outbound manner as well; where you are able to communicate with your compliance customer base, your employees. You should work to incorporate one or more of the techniques listed herein to help you burn compliance into the DNA fabric of your organization.

Once again please remember that I am compiling a list of questions that you would like to be explored or answered on the use of social media in your compliance program. So if you have any questions email them to me, at tfox@tfoxlaw.com, and I will answer them within the next couple of weeks in my next Mailbag Episode on my podcast, The FCPA Compliance and Ethics Report.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2015

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