Welcome to Episode 9 of Compliance Man Chooses the Target with Tim Khasanov-Batirov.The goal is to highlight matters that should be on agenda of practitioners that deploy compliance programs in industries or countries of active anticorruption enforcement. In this podcast series, Compliance Man will target three specific matters that you might like to address in the course of implementation of your compliance program. Today we will focus on improvement of daily compliance activities.
Target #1: Communications with Colleagues
It is about trust. Success of your corporate compliance program depends on whether your colleagues feel comfortable to approach you without fear. You might have a pile of policies but in the reality of any company, specifically when we talk about emerging markets personal trust to Compliance officer is essential. On practice, this allows to implement proactive rather than reactive approach, when personnel approaches compliance officer with their ethical dilemmas prior to acting.
Target #2: Generation Y
Recently I was teaching Compliance class at the Summer School at Baltic Federal University. I have noticed that for generation Y and specifically for those who were born in 1990-s methods of teaching/training compliance should differ from techniques used for people of older age. The main difference is that youngsters are able and used to deploy internet search much more actively comparing to older folks. In addition generation Y feels comfortable to self-educate themselves due to availability of gadgets using which they can google virtually any compliance related information. I would suggest having in mind the above mentioned in the course of preparation of compliance trainings to young personnel.
Target #3: Keep your Compliance Eyes Open
The biggest mistake compliance officer could make is to limit himself to a couple of areas, which historically are associated with compliance department’s area of responsibility as drafting anticorruption policies for instance without paying attention to business processes, projects, corporate initiatives which might also contain FCPA risk but needs analytical efforts from Compliance officer to be spotted. It is much easier in daily routine to look solely on gifts practices as it contains a compliance associated ‘hashtag’ GIFT than to mitigate risks integrated in business processes. Such situation is depicted in one of the releases of Compliance Man illustrated series http://complianceinpostussr.com/compliance-man-of-integrity-corp-episode-7-mistakes/#comment-19
The best way to manage the ‘hashtag’ approach is a compliance risk register. Just go to the process, project or corporate initiative where the FCPA risk might take place. Keep your compliance eyes open to evolving corporate reality.
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