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 and hints. This concept can be particularly helpful in relating to and with cultures outside the U.S. as one of the most critical issues to a compliance function is breaking through a company’s internal cultural boundaries. In a  Harvard Business Review article, entitled “Getting to Si, Ja, Oui, Hai and Da”, 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. In its 2020 Update, the DOJ specified that when it comes to compliance training, a company must offer compliance training in the form and language appropriate for the audience.

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.

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.

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