A 360 degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is about creating a distinctive brand philosophy of compliance which is centered on your consumers. In other words, it helps a compliance practitioner to anticipate all the aspects of your employees needs around compliance. This is especially true when compliance is either perceived as something that comes out of the home office or is perceived as the “Land of No.” A 360-degree view of compliance gives you the opportunity to build a new brand image for your compliance program. This is important as the Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance) mandates that for a compliance program to be effective, it must be understood by a wide variety of stakeholders.
Communications is often thought of as a two-way street – upward and downward, inbound and outbound, or side-to-side. However, it is better to think of it as a 360-degree effort. You simply can no longer effectively communicate in just two ways. You now communicate in a more holistic manner, and in multiple ways. If you are just thinking about communications in the classic form, you are missing something that is happening around you.
360-degrees of compliance communication is not just a classic form of communication but rather it is a communication in the concept of every interaction, whether they be planned or accidental interactions. It is all a form of communication. This is particularly true if you are a compliance professional, practitioner or Chief Compliance Officer. The things you do, the way you act, and the way people see you, you are always communicating. It is not simply communicating one to one as often you may be communicating to a group across siloed boundaries, to the constituencies you had not even planned to communicate with initially.
There are several concepts which should be included in your 360-degree view of compliance communications. Begin with an objective so you identify the purpose of your communication and the target of whom you are going to communicate to. Identify as clearly as you can the purpose and reason to ensure your message is aligned with your objectives. For instance, are you implementing a 360-degree view of communication to educate, inform, change perceptions or build trust and commitment?
Next, who is your audience? To communicate effectively, you need to understand your audience. In any corporation, there are multiple audiences who are the key stakeholders in the 360-degree process. How much do they know? Some of the stakeholders include the Board of Directors, senior and middle management, employees, committees, coaches, facilitators, customers, business partners, vendors, sales agents and representatives, strategic alliances and business ventures. What are your distribution channels and how do you track your messaging? You should create a comprehensive method to track the intended audience and delivery mechanism. Another key ingredient of the 360-degree approach is feedback. This is a key component to educate each stakeholder on the benefits of feedback from the 360-degree approach.
Finally, you need to evaluate what you have done. You can monitor your communication activities by tracking attendance at events, website statistics, open rate of emails, downloads of materials, video hits; in other words, the same techniques that your marketing folks would use to determine their messaging’s effectiveness. The objective is to build trust for the 360-degree process by determining if the goal was achieved. You can utilize surveys or focus groups to assess the impact on your target audience. By focusing on your customers of compliance (i.e., your employees), it allows you to identify gaps and improve the communication process for your compliance program.
Using such an approach allows a CCO to “see around corners” and can be one of the greatest strengths of a best practices compliance program. The reason is listening. Listening is a key leadership component and there are certainly many ways to listen. You can sit in your office and wait for a call or report on the hotline or you can go out into the field and find out what challenges employees are facing. From this you can work with them to craft a solution that works for the company and holds to the company’s ethical and compliance values.
The best example I can provide to you is a story told to me by Louis Sapirman, Vice President and Chief Ethics and Compliance Officer at Panasonic Corporation of North America. This story happened to him in Argentina, which he was the CCO at Dun & Bradstreet (D&B). 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 exchange rate, 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 D&B 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:
- Remember the definition of 360-degrees of communication. It is an effort that moves the compliance identity into a holistic approach so compliance is in touch and visible to your employees at all times.
- What is your objective? What are you trying to do with your 360-degrees of communications and how are you using that mechanism to deliver the objectives of your compliance program?
- Evaluate. You need to evaluate three factors: 1) has the message been delivered; 2) has it been heard; and 3) is it being implemented?