I entitled this month’s podcast series as “360-degrees of communication in compliance” because it has occurred to me that you can have an ongoing discussion about compliance at all times. Previously, I had thought of communications really as a two-way street upward and downward inbound and outbound side to side. However, you might choose to phrase it, a 360-degree approach is something different. I do not think you communicate in just two ways any longer. I think you communicate in multiple ways. If you are just thinking about communications in the classic form you’re missing something that is happening around you. Today, I want to consider what we have learned.

360-degrees of communication and compliance is not just a classic form of communication but rather it’s a communication in the concept of every interaction whether they be planned interactions or whether they be into or accidental interactions. It is all a form of communication. This is particularly true if you’re a compliant professional a chief compliance officer or a compliant practitioner. The things you do the way people see you you’re always communicating and it’s not just communicating to one another often you’re communicating to a group across group boundaries to the constituencies you had not even planned to initially communicate with.

A 360-degree approach takes a much more holistic approach as opposed to just you and me; up and down inbound and outbound; side to side communication. Over this month, we have explored multiple forms of 360-degrees of communication, looked at social media, considered the concept of sharing. We have explored the clash of cultures and how communication a 360-degree approach to communication can help overcome that. We have discussed storytelling in compliance and teaching lawyers how to communicate and compliance. We have reviewed such leadership topics as persuasion, self-reliance and then multiplying the influence of compliance.

We have also considered communicating across cultural boundaries how you can use social media tools such as Twitter even things that you might not consider a communication tool such as the supply chain and how innovation in your supply chain around communication can be used for your organization. You probably have not considered crowdsourcing as a form of 360-degrees of communication so. It has been a fascinating exploration and some of the things that I think he may not have considered as communication.

Concepts such as utilizing communications to see around hard walls that because of a 360-degree approach you can certainly allow you to obtain more information. Communications can not only enhance your training but expand your training. If you think of all forms of communication as training you can quickly begin to see that your interactions with your employees are not only a form of training but they are really a form of ongoing communications and if you take the 360-degree approach you are continually communicating about your culture you’re continually communicating about your values and your modeling for your employees the behaviors you want to see. So, think about expanding your training repertoire by making it not training but a 360-degree approach.

Always remember that the Department of Justice looks at your training. But more importantly they look at your compliance communications. Never forget the 2012 Morgan Stanley declaration where they specifically pointed out 35 compliant reminders emailed to a recalcitrant employee over seven years. What if your communications is a 360-degree approach which allows you to document a continual form of communication and a continual stream of communication to your employee base. The government ever comes knocking. You have that record every time you utilize a social media tactic or technique, within behind your firewall or any other form of communication whether it be video, audio, e-mail, written document, or other.

It is a very powerful way for you not only to get your message across but also for you to protect yourself and protect your organization. When you can utilize a tool or technique which not only helps you get your message out but also helps you to further protect the company that’s a tool that I think is of high value to you.

I would like to end this month with a story that was told to me by Louis Sapirman, the CCO at Dunn & Bradstreet. And it happened to him in Argentina. Argentina has an interesting form of illegal conduct, which is an open black market for the changing of currency. Sapirman was with a colleague who was one of the leaders from the company’s South American operations and they went into a convenience store. The person who was going to sell him the product suggested that he go just around the corner and change money on the black market where he could get a much better rate was almost a 100 percent difference in the exchange rate; he declined to do so. Sapirman paid and received the established bank right in the small transaction.

He had not considered role modeling that compliance. About six months later one of his team members was in Mexico speaking to the leader of the Dunn and Bradstreet operation there. The non-compliance function employee said that he was the person who had been with Sapirman. He recounted the story of doing the right thing, when literally no one was watching. That is the power of 360-degrees in communication.   

Three Key Takeaways

  1. 360-degrees of communication is a much broader manner of thinking about communications.
  2. You can use 360-degrees of communication to both see around walls and expand your training regime.
  3. You are always communicating 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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