How has one company and one CCO actively use social media to make the company’s compliance culture more effective? The company was Dun & Bradstreet, Inc. (D&B) and its then CCO, Louis Sapirman, who discussed D&B’s integration of social media into compliance with me.
These tools can go a long way towards enhancing your compliance program going forward. Recall the declination to prosecute that Morgan Stanley received from the DOJ, when one of its managing directors had engaged in FCPA violations. One of the reasons cited by the DOJ was 35 email compliance reminders sent over seven years, which served to bolster the annual FCPA training the recalcitrant managing director received. You can use your archived social media communications as evidence that you have continually communicated your company’s expectations around compliance. It is equally important that these expectations are documented.
Finally, never forget the social part of social media. Social media is a two-way communication. Not only are you setting out expectations but also these tools allow you to receive back communications from your employees. The D&B experience around the name change for its Code of Conduct is but one example. You can also see that if you have several concerns expressed it could alert you earlier to begin some detection and move towards prevention in your compliance program.
Three key takeaways:
- How does 360 degrees of communication work in compliance?
- Focus on the ‘social’ part of social media.
- Use internal corporate social media to have a conversation.