A 360-degree approach to communications entails looking at all forms of interactions as a way to interconnect. This means both verbal and non-verbal and in clues, hints in addition to directly. This concept can be particularly helpful in relating to and with cultures outside the United States as one of the things most critical issues to a compliance function is breaking through a company’s internal cultural boundaries. In “Getting to Si, Ja, Oui, Hai and Da; How to negotiate across cultures”, Erin Meyer explained that “managers often discover that perfectly rational deals fall apart when their [business] counterparts make what seem to be unreasonable demands or don’t respect their commitments.” She laid out a five-point solution that I have adapted for the CCO or compliance practitioner in communicating a compliance program across a multi-national organization.

Initially look for as many cultural bridges as you can find as it will help you understand what your international audience is communicating to you, in both verbal and non-verbal formats, during a wide variety of activities familiar to any compliance professional such as training, investigations or simple meetings where the compliance perspective must be articulated in any business setting. If you fail to have an understanding or even a person who can navigate these signs for you, here are five steps to help you out: (1) Adapt the way you express disagreement; (2) Know when to bottle it up and let it all pour out; (3) Learn how the other culture builds trust; (4) Avoid yes or no questions; and (5) Be careful about putting it in writing.

Adapt the way you express disagreement

Simply because someone disagrees with you, it is not a sign that the discussion is going poorly but that it is an invitation to engage in a lively talk. The key is to listen for verbal cues when interacting. These sources are “what linguistics experts call “upgraders” and “downgraders.” Upgraders are words you might use to strengthen your disagreement, such as “totally,” “completely,” “absolutely.” Downgraders – such as “partially,” “a little bit,” “maybe” – soften the disagreement.” It is incumbent to understand upgraders and downgraders within their own cultural context.

Know when to bottle it up and let it all pour out

Some cultures have very demonstrative ways of speaking and gesturing. However other cultures are not comfortable with such displays. You need to understand this key difference. Meyer writes, “So the second rule of international negotiations is to recognize what an emotional outpouring (whether yours or theirs) signifies in the culture you are negotiating with, and to adapt your reaction accordingly. Was it a bad sign that the Swedish negotiators sat calmly across the table from you, never entered open debate, and showed little passion during the discussion? Not at all. But if you encountered the same behavior while negotiating in Israel, it might be a sign that the deal was about to die an early death.”

Learn how the other culture builds trust

Most Americans think that building trust in a business setting is gained by demonstrating your usefulness and competency in providing solid information. However, this type of approach is not always the most effective across the globe. There are two different approaches to building trust:  cognitive and affective.

In the cognitive approach, you gain trust by “the confidence you feel in someone’s accomplishments, skills and reliability.” In short, you know your stuff and for the compliance practitioner there is usually not much higher a compliment. This type of trust is more valued by Americans, Germans, Australians and Brits. Meyer says this is the trust that comes from the head. Conversely, affective trust may be termed to come from the heart. But it is not simply emotive. It derives from “emotional closeness, empathy, or friendship.” It means that you see each other on a personal level. In the BRIC countries, Southeast Asia, trust of this type is not likely to be achieved until this type of connection can be made.

Some of the techniques you can employ to build trust are to, “Invest time in meals and drinks (or tea, karaoke, golf, whatever it may be), and don’t talk about the deal during these activities. Let your guard down and show your human side, including your weaknesses. Demonstrate genuine interest in the other party and make a friend. Be patient: In China, for example, this type of bond may take a long time to build. Eventually, you won’t have just a friend; you’ll have a deal.”

Avoid yes or no questions

This is something Americans have an innate amount of trouble getting our heads around. Most generally when we ask a direct question requiring a direct Yes-or-No answer; we expect that whichever the answer is, it will be adhered to going forward. In many other cultures that may not always be correct. In some cultures, it is rude to tell someone you respect and have trust for ‘No’ directly. While they may say ‘Yes’, they may really mean ‘No’. Conversely, even when the verbal response is a strong or even a multiple ‘No’ answer, it may simply mean that the party needs more time to respond.

This means you should try to avoid a simple Yes-or-No response, by asking a more open question that elicits additional information that will help provide the context for the answer. You should also watch body language and other signals more closely, “Even if something is affirmative, something may feel like no: an extra beat of silence, a strong sucking of breath” or a muttering. Be watchful and listen closely.

Be careful about putting it in writing

This last point may be the most difficult for the CCO and compliance practitioner, especially if you accept my mantra to Document, Document, and Document. In many cultures, even the follow up to a conversation with something in writing could well seem like a slap in the face, the lack of trust or even communicating that the listener did not comprehend what you were communicating. You may need to do some additional amount of explanation around your written compliance documentation. Do not be dogmatic about it, but emphasize the need for written materials in the appropriate situation.

Communications in compliance must be largely drawn around trust. For any compliance practitioner, this is a key to working with your employee base across the globe. Implicit in building trust is that you get out of your home office and travel to your other office locations. While you can build cognitive trust through demonstrating your usefulness to an overseas business unit from your home office in America, you will never build affective trust sitting in the corporate office. Get out and about and meet your employees and build the trust that will allow a successful a 360-degree approach to communication.

Three Key Takeaways

  1. Communications in compliance must be largely drawn around trust.
  2. Look for as many cultural bridges as you can find as it will help you understand what your international audience is communicating to you.
  3. One of the things most critical issues to a compliance function is breaking through a company’s internal cultural boundaries. 


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.