One of the greatest things about the compliance profession is that it is only limited by its collective imagination. If you can think it up, you can probably do it. This has led not only continuing evolution of compliance programs but continuing innovation in the compliance function. As compliance programs evolve and innovate, regulators take note and the cycle becomes almost a continuous feedback loop. One technique new to compliance but squarely in the 360-degree view of communication is internal crowdsourcing, to enlist new ideas from employees, to open new sources of compliance innovation.

Internal corporate crowdsourcing was explored in  “Developing Innovative Solutions through Internal Crowdsourcing, where the authors noted, “It allows employees to interact dynamically with coworkers in other locations, propose new ideas, and suggest new directions to management. Because many large companies have pockets of expertise and knowledge scattered across different locations, we have found that harnessing the cognitive diversity within organizations can open up rich, new sources of innovation. Internal crowdsourcing is a particularly effective way for companies to engage younger employees and people working on the front lines.” They came up with seven key elements companies should use to aid in moving such an effort forward, which apply forcefully to the CCO and compliance practitioner.

  1. Keep the focus on innovation. You should use this technique for long-term initiatives and not short-term improvements. Establish the grounds for employee creativity with criteria such as (1) ability to meet employees’ unmet needs, (2) delighting the employee, (3) the solution’s newness, (4) marketability, (5) commercial viability, and (6) scalability.
  2. Give internal crowdsourcing participants slack time. If your company wants you focused solely and only on your day job, it will, by definition, limit your participation in a company crowdsourcing project to nights and weekends. This may not be when and where you do your best work. Companies must arrange to allow employees the time and space during working hours to participate meaningfully.
  3. Allow for anonymous participation. Trust is always a key issue in these types of project. Anonymous participation can help build and maintain that trust because when organizational identities are revealed in an internal crowdsourcing project, “some individuals may feel compelled to defend their formal positions.” Companies need to ensure participants “feel safe about contributing knowledge, regardless of their seniority or role in the company.”
  4. Take steps to ensure that company experts don’t exert their influence too heavily. Internal company experts will have their ideas given additional heft if their identities are known. This can have the unintended effect of intimidating others or lessening their voices in the process. Yet you must work to keep the process open to diverse perspectives, for internal crowdsourcing to produce innovative outcomes. You should have the company’s compliance experts operate as moderators and to do what they can to encourage others to come up with compliance innovations.
  5. Use a collaborative process for internal crowdsourcing. Much like Louis Sapirman’s use of social media to communicate with and obtain information from D&B’s employee base, use of an internal crowdsourcing project has the positive by-product of engagement, stating, “It’s also to build a system through which people within the organization share knowledge, learn from one another, and offer pertinent knowledge for use in new solutions.” If you can engage your employees in compliance, you will not only have a better chance of keeping them engaged, but you will also more fully burn compliance into the fabric of your organization or operationalize compliance in your organization.
  6. Design platforms that facilitate shared development and evolution of solutions. A key to internal crowdsourcing success draws inspiration from open source software. It is that employees need to see what other employees have contributed so they can build upon it. You must find a way to share knowledge among the employee base on an ongoing basis. The authors found three major benefits to such an approach: “(1) knowledge sharing among the crowd across a variety of knowledge types (not just ideas); (2) the opportunity for coevolution of solutions by the crowd; and (3) the degree to which feedback from the crowd helps to refine ideas.”
  7. Be transparent about plans for follow-up post-crowdsourcing. Not surprisingly, one major defect around internal crowdsourcing projects is lack of follow-up and lack of transparency for the employee participants. Simply put, employees not only want to know the results but they also want to know if their ideas were used. This can be a powerful motivator for future participation or the opposite. Companies need to make the process open and fair.

By internally outsourcing compliance function enhancements, a CCO can increase employee engagement in compliance. The entire process draws from your diverse employee base which brings both organizational learning and knowledge diffusion into the continuous improvement of your compliance program. Just as the data in your organization is your data, so you should not only utilize it but monetize it; your employee base can be a large and untapped source of information which can more readily be implemented and have a more rapid impact on your compliance program going forward.

Three Key Takeaways

  1. In compliance, you are only limited by your imagination.
  2. Build trust and be transparent in your process.
  3. Through internally outsourcing compliance function enhancements, a CCO can increase employee engagement in compliance.

 

This month’s podcast series is sponsored by Dun & Bradstreet.  Dun & Bradstreet’s compliance solutions provide comprehensive due diligence reporting and analysis to reduce your risk of working with fraudulent companies by accessing a company’s beneficial ownership, reputation risk and more.  For more information, go to dnb.com/compliance.

 

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