Much Ado About NothingHow does Shakespeare portend social media in the 21st century? I would submit that one only need look at Much Ado About Nothing to see how it should all play out. As with all Shakespeare’s plays there is quite a bit going on but the play centers around the action and dialogue of Benedick and Beatrice who go after each other in a manner which shames modern NBA trash-talkers. Apparently everyone else in the play understands the two are meant for each other so they engage in a very social media style of communication to put the two together. Of course, as this is a comedy, everyone ends up married so Beatrice and Benedick, prompted by their friends’ interference, finally, and publicly, confess their love for each other.

Yesterday I wrote about ways to think through using social media in your Foreign Corrupt Practices Act (FCPA) anti-corruption compliance program. Today I want to explore how one company and one Chief Compliance Officer (CCO) actively uses social media to make more effective the company’s compliance regime. The company is the venerable Dun & Bradstreet (D&B) and its CCO, Louis Sapirman, whom I visited with about his company’s integration of social media into compliance.

Initially Sapirman emphasized the tech savvy nature of the company’s work force. It is not simply about having a younger work force. If your company is in the services business it probably means an employee base using technological tools to deliver solutions. He also pointed to the data driven nature of the D&B business so using technological tools to deliver products and solutions is something the company has been doing for quite a while. This use of technological tools led the company to consider how such techniques could be used internally in disciplines which may not have incorporated them into their repertories previously.

Not surprisingly, with most any successful corporate initiative, Sapirman said it began at the top of the organization, literally with the company’s Chief Executive Officer (CEO), Robert Carrigan. Sapirman noted that the CEO saw the advantage of using social media internally and challenged many in his organization to take a new look at the manner in which their functions were using social media. From there Sapirman and his team saw the advantages of using social media for facilitating a two-way communication. Moreover, Sapirman comprehended the possibility for use of social media for compliance with those external to the company as well.

Internally Sapirman pointed to a tool called Chatter, which he uses similarly to those in Twitter engaging in a Tweet-up. He has created an internal company brand in the compliance space, using the moniker #dotherightthing, which trends in the company’s Chatter environment. He also uses this hashtag when he facilitates a Chatter Jam, which is a real-time social media discussion. He puts his compliance team into the event and they hold it at various times during the day so it can accessed by D&B employees anywhere in the world.

He said that he ‘seeds’ Chatter Jam so that employees are aware of the expectations and to engage in the discussion respectfully of others. When they began these sessions he also reminded employees that if they had specific or individual concerns they should bring them to Sapirman directly or through the hotline. However he does not have to make this admonition any more, as everyone seems to understand the ground rules. Now this seeding only relates to the topics that each Chatter Jam begins with going forward.

One of the concerns lawyers tend to have about the use of social media is with general and specific topics coming up on social media and the ill it may cause the organization. Sapirman believes that while such untoward situations can arise, if you make clear the ground rules about such discussions, these types of issues do not usually arise. That has certainly been the D&B experience.

Each employee uses their own names during these Chatter Jams so there is employee accountability and transparency as well. Sapirman said they further define each communication through a hashtag so that it can not only immediately be defined but also searched in the archives going forward. He provided the examples of specific regulatory issues and privacy. This branding also enhances the process going forward.

I asked Sapirman if he could point to any specific compliance initiatives that arose during or from these Chatter Jams. Sapirman emphasized that these events allow employees the opportunity to express their opinions about the compliance function and what compliance means to them in their organization. One of these discussions was around the company’s Code of Conduct. He said that employees wanted to see the words “Do The Right Thing” as the name of the Code of Conduct.

I inquired about D&B’s use of social media in connection with their third parties. Sapirman said that the company allows some of them access to its internal Chatter tools to facilitate direct communications. Further, these external contractors can connect with both Sapirman and the company through Twitter. He said that he is consistently communicating to the greater body of customers about the compliance initiatives or compliance reminders on what the D&B compliance function is doing and how it is going about doing them. He believes it is an important communications tool to make sure that he and his team are getting their compliance messages out there.

Sapirman also described using Chatter in a manner that sounded almost like Facebook and its new live video function. He said they can deliver short video vignettes about compliance to employees. The compliance function or the employee base can develop these.

All of the initiatives Sapirman described drove home to me three key insights. The first is how compliance, like society, is evolving, in many ways ever faster. As more millennials move into the workforce, the more your employee base will have used social media all their lives. Once upon a time, email was a revelatory innovation. Now if you are not communicating, you are falling behind the 8-ball. Employees expect their employers to act like and treat them as if this is the present day, not 1994 or even 2004.

The second is that 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 Department of Justice (DOJ), back in 2012, 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 7 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 (Read – Document, Document, and Document).

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 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.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2016

Henry VMost people remember the St. Crispin’s Day speech in Henry V as one of the greatest speeches in all of Shakespeare. However many people do not focus on what led to that speech which was that Henry went out among his troops, disguised as a commoner to ask they what they thought and to hear what they had to say about the upcoming battle with the French. One of the most important things that Henry learns is that his men, while willing to do their duty, believe they will all die the next day in battle, most particularly because of the overwhelming size differential in the two armies. Henry takes this information and incorporates those fears, together with English patriotism, into the rousing speech he gave before he led his men to victory.

I am a huge fan of using social media in your compliance function. I often point to Louis Sapirman, the Vice President (VP), Associate General Counsel (AGC) and Chief Compliance Officer (CCO) at Dun & Bradstreet, as an example of a company and CCO that has embraced the use of social media to advance their best practices compliance program.

CCOs and compliance practitioners often ask me how they could begin to get their arms around how to structure such a program for their company. In an article in the MIT Sloan Management Review, entitled “Finding the Right Role for Social Media in Innovation”, Deborah Roberts and Frank Pillar reviewed companies that were not deriving significant benefit from their customer facing social media efforts. I found their discussion of potential remedies as a useful tool to help CCOs design an internal company wide social media campaign.

After acknowledging that social media focuses on the social aspects of the communication, I think the most important thing to remember is that communication in social media is two-way; both inbound and outbound. It can help to bring your employee base together in an efficient manner to create an environment conducive to compliance for your organization. It also has the benefit of continued engagement. It is more than putting on training or even a Compliance Week set of initiatives, you can continue the conversation and enthusiasm about compliance going forward.

The authors break this down further into three parts that emphasize (1) the need to listen to and learn from user-generated content; (2) the need to engage and facilitate dialogue with employee innovators; and (3) to find an audience of early adopters to create excitement and collect feedback. No doubt inspired by some fond childhood memories, the authors monikered these three concepts as (a) Camp Explore, (b) Camp Create and (c) Camp Communicate.

Camp Explore

This is the method the authors suggest of how to generate employee insights into your compliance program “where activities are designed to extend the breadth and depth of how organizations search for innovations” even in the compliance arena. The key is that the compliance function must be listening and listening in a manner which they may not have used previously. The authors write that you will need to “learn to read the signals from large, diverse, disconnected, and unstructured pools of data generated by users. In addition, they will learn to analyze and convert blog posts, tweets, and user-generated content into valuable insights for new products.”

Compliance professionals will need the skills of both a social scientist and a data scientist at Camp Explore. This is because compliance practitioners will need to “assimilate, combine, and utilize data from many different sources” across the globe. The authors noted, “they will need to acquire skills in computational techniques to unveil trends and patterns within and between the various data sets.” The overall award from Camp Explore “is to sharpen their business acumen and teach them how to communicate the findings to those involved in [compliance] projects.”

Camp Cocreate

If a company has matured past Camp Explore, the next step the authors suggest is Camp Cocreate for companies that “know they actively want to engage and involve [employees] in the innovation process” around compliance. The overall goal is to be more collaborative to allow employees to be more involved in the design process. As a CCO or compliance professional you will “learn how to engage, identify, and select the right participants and develop the right incentives to encourage their participation. Creativity is both an input and an output of the cocreation process. Managers will also develop skills in relationship building and gain experience in the art of conversation and dialogue, a key aspect of collaboration. Managers will learn how to become better facilitators and community managers.”

One of the important factors is to visit with “unconventional users” to help facilitate the creative process. Here social media itself can be a powerful tool, facilitating a two-way communication street to allow the compliance function to hear and even see what business and other types in the field may see and hear. The model of involving employees for in-house innovation has always been useful to help build buy-in and acceptance but the authors also found that more diverse participation in the creation process can provide a richer developed process. 

Camp Communicate

This learning camp focuses on the most obvious uses of social media, to communicate and tell a story. The authors write, “As social media becomes an ever more integral part of people’s work and social lives, people have come to expect communication about products and brands via social media channels.” Social media can also afford the compliance function the opportunity to interact more directly with its customer base, the company’s employees, in a manner that is far more engaging than the old command and control approach.

If your goal in the compliance function is to create awareness and publicize your compliance program and initiatives, social media can be a powerful tool for you. Indeed the authors believe it should be a “core activity.” Through the use of social media tools, your compliance function can not only tell the story of compliance but also communicate expectations and even train. Yet once again it is simply more than a one-way tool as using social media facilitates a two-way communication. Just as employees are more apt to tell you about a concern immediately or soon after they have been trained on that issue; they may well communicate directly with you after having received a social media communication on subjects such as managing of third party relationships.

The authors end their article on a cautionary note. They believe many companies are approaching social media in the same manner as they approached the dot-com boom of the 1990s. Companies are embracing the technologies but simply following the herd, “In the case of social media, they embrace whatever social media sites and strategies are in vogue without developing a coherent strategy for tying their social media activity to new product development. Having a Facebook page, creating a brand community, or having a social media page dedicated to a new [compliance] launch will not, on its own, improve a company’s [compliance] performance.”

CCOs and compliance practitioners need to develop a dedicated compliance strategy around social media, in the context of your corporate objectives. Just as Henry V gave one of the most rousing speeches in all of Shakespeare, basing it on the input he received from his men, you can take the input from your employee base and create a compliance experience that your employees will embrace.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2016

Social Media VII conclude this exploration of the uses of social media in doing compliance by exploring why the compliance function is uniquely suited to using social media tools. Long gone are the days when Chief Compliance Officers (CCO) or compliance practitioners were lawyers housed in the Legal Department or the General Counsel’s (GC’s) office writing policies and procedures and then putting on eight hour training programs on same. Donna Boehme has written passionately about CCO 2.0 and the structural change to separate the CCO role from that of the GC because of the differences in focus of a CCO and GC. Simply put, a GC and legal department is there to protect the company while the CCO and compliance function exists to solve problems before the company needs protections from them.

Freed of the constraints to write policies and procedures by lawyers for lawyers, the profession has moved to integrating compliance directly into the fabric of the company. I often say that a Foreign Corrupt Practices (FCPA) compliance program is a business solution to a legal problem. The problem is how to comply with the FCPA and other anti-corruption regimes. The solution is to burn compliance into the DNA of your company so that it is not only owned by the business unit but also acted on by the business unit in its day-to-day operations.

I think this means that we are now moving to CCO 3.0 where a CCO or compliance practitioner is putting compliance into the forefront of how a company does business. The example of safety comes to mind when every corporation I ever worked at made clear that safety was everyone’s responsibility, literally from the shop floor to top of the company. I once heard of a Executive Vice President (EVP) of a major oil and gas operating company, while touring a contractor’s facility, stop the tour to point out that a contractor carry two bags of trash down a set of stairs was an unsafe practice and required the employee to carry one bag at a time so she could hold the handrail while descending the stairs. That is the level of the awareness of safety now.

The evolution of compliance is just as dramatic. Moreover, the compliance function should be on the cutting edge of moving it forward within your company. The important thing to remember about social media tools is precisely that; they are tools that a CCO, compliance practitioner or any company can use to communicate with their employee base. Put another way, social media is but one part of the communication ecosystem which can be used to market the message of compliance.

Last week I wrote that there are still many companies who do not allow their employees access to the most popular and useful social media tools at work or even on company computers. While these companies always claim it is due to security issues, the reality is that they simply do not trust or even respect their employees. In such a company, management is much more concerned about what employees might say about an organization than trusting that they not only want to do the right thing but will execute such a strategy when provided the opportunity to do so, through the mechanism of social media. This means that companies which trust and respect their employees do not have to worry about employees releasing confidential data through social media channels because there are plenty of other ways that employees can release confidential information if they were so inclined. Indeed think of the Dodd-Frank Whistleblower provision and how many employees who report to the Securities and Exchange Commission (SEC) reported or tried to report internally before going to the SEC. Simply put if a company does not trust and respect its employee base, communicating the message of compliance throughout an organization will be more difficult but that is clearly not the signal senior management is sending to its employees.

The compliance function must engage with its customer base, AKA the employees in a company. Charlene Li, in her recent work “The Engaged Leader”, said in the introduction “In order to be truly effective today, leaders in business and society must change how they engage, and in particular how they establish and maintain relationships with their followers via digital channels.” The same is true for the compliance function. She believes that technology has changed the dynamic between leaders and their followers. In The Engaged Leader she explains:

  • Why leaders need to master a new way of developing relationships, which begins by stepping out of traditional hierarchies
  • How to listen at scale, share to shape, and engage to transform
  • The art of making this transformative mind shift
  • The science of applying the right tools to meet your strategic goals

Li believes that “This transformation is not optional. Those who choose not to make this change will be abandoned for those who inspire people to follow them.” In an interview for the podcast HBR Ideacast, entitled ““Social Media Savvy CEO” is no Oxymoron, Li further expounded on these views. She asked why a leader would be afraid to engage with those in his or her corporation? But more than simply engagement, she asked why would a leader want to cut themself off from the best source of information for them and available to them; their employee base, through social media. After all, every company strives to have an active engagement with their customer base so why not have it with employees.

Now change out Li’s language from ‘leaders’ and insert ‘CCOs or compliance practitioners’. I think it is even more critical for the CCO or compliance practitioner because doing compliance is something that should occur in the business units. Yes a CCO can put those policies and procedures in place but it is the folks in the field who must implement them going forward. If social media can be a tool to help facilitate doing compliance why not embrace it for communications, training, input, problem identification or resolution?

Yet there is another reason for the compliance function to embrace social media going forward. One of my favorite thought leaders around innovation in the legal arena is Professor David Orozco. In a blog post, entitled “Innovation in the Legal Sector”, he said, “Innovation is a big deal. It’s been a big deal ever since customers rewarded differentiation and punished companies that failed to maintain their creative edge.” The same is equally, if not more so, applicable to the compliance arena. The Department of Justice (DOJ) has consistently made clear that FCPA compliance programs should be evolving and using the newest and best tools available. That sounds suspiciously like social media to me. So if these tools are available to you and at a very reasonable cost (i.e. free) why not consider using them. If you are afraid of information getting out of your company, why not consider using the social media concepts behind your firewall in your company intranet system?

Finally, even if you cannot use some of the publicly available tools discussed earlier, there is no reason that you cannot incorporate the concepts into your compliance program. By that I mean you can use the communication ideas inside of your company for your compliance program. You can create the equivalent of a Tweet-Up where the CCO or others answer questions that employees submit. Similarly, you can live stream a Q&A session using the concepts articulated by Meerkat and Periscope for social media live streaming. Pinning compliance reminders or other information in some type of internal company bulletin board is using the basic concept of Pinterest. I am sure that you can accomplish the same by using SharePoint. Why not create an internal compliance reminder video series using the same tools that a millennial would use to create a Facebook post?

Think all of this sounds far-fetched? Think again. In this month’s issue of the Compliance Week magazine, Guest Columnist Raphael Richmond, the CCO at Ford Motor Company, in an article entitled “Compliance? There Should Be an App for That!, detailed how the company has created an app for iPhone and Android devices that “allows users to access compliance information quickly, including brief, easy-to-understand policy summaries and answers to frequently asked questions (FAQs). The app also has a “Can I … ?” tab that acts as a quick decision tree for finding specific answers to commonly asked questions. Topics in our app address a range of compliance issues, from anti-bribery guidance to Ford’s approach to gifts and favors, meals, travel, and social events. Individuals can also report a suspected violation directly from the app to the Corporate Compliance Office.” It will certainly be exciting to see how Ford develops this tool going forward.

I often say that as a CCO or compliance practitioner you are only limited by your imagination. The use of social media in your compliance function is one that is crying out for imaginative usages. As we move to CCO 3.0, the compliance function will need to avail itself of all the tools it can to communicate the message of compliance. The DOJ currently requires companies that enter into Deferred Prosecution Agreements (DPAs) to keep abreast of technological innovations in compliance. How long do you think it will take for the DOJ to start asking how much compliance communication you have both up and down the chain? If you are not using a social media tool or even a social media technique you may already be behind the 8-ball and you certainly will be left behind in the marketplace of ideas going forward.

I hope that you have enjoyed this six-part series on the use of social media in your compliance program as much as I have enjoyed researching it, writing and posting it. If you are currently using social media tools, concepts or techniques in your compliance program please contact me, as I would appreciate the opportunity to learn more about what your organization is up to in that realm. Also, please remember that I am compiling a list of questions that you would like to be explored or answered on the use of social media in your compliance program. So if you have any questions email them to me, at tfox@tfoxlaw.com, and I will answer them within the next couple of weeks in my next Mailbag Episode on my podcast, the FCPA Compliance and Ethics Report.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2015

Social Media 5-IconsTo conclude this week’s posts, I wanted to list some of the more prevalent social media tools, explain what they are and how you might use them in a compliance program. (As usual I got carried away so this series will conclude on Monday of next week.) You need to remember that your compliance customer base are your employees. The younger the work force, the more tech savvy they will be and the more adapted to communicating through social media. According to Social Media Examiner’s 2015 Social Media Marketing Industry Report, the top two social networks for marketing are Facebook and LinkedIn. The three social media tools that hold the top spot for social media planning are LinkedIn, YouTube and Twitter. Marketers report that video streaming is becoming increasingly important tools for markets and that is currently encompassed in Meerkat and Periscope. Finally, I would add that Pinterest is another hot social media app.

Facebook

If you do not know what Facebook is at this point, you may have just transported down from a Borg Cube or perhaps you are a Vulcan looking for First Contact. This is the world’s most ubiquitous social media tool. It combines both personal and business applications. For the compliance practitioner, think about the business uses of Facebook. You can open a Facebook page for your compliance function and share an unlimited amount of information. Equally importantly, you can be responsive when employees comment on your posts, it allows you to interact with them and demonstrate that compliance is listening and responsive. The more regularly you post, the more opportunity you have for connecting with your employee base and building trust.

YouTube 

Much like Facebook, YouTube is one of the most ubiquitous social media tools around. It allows you to upload video and audio recordings for unlimited play. For the compliance practitioner, why not consider creating a YouTube channel for your company’s compliance program. You can put together full training on specific issues or you can create short videos. For an example of short videos, you can check out the training videos I have on my website Advanced Compliance Solutions. If there is any information that you wish to put into a visual format, YouTube is one of the best solutions available to you.

LinkedIn

LinkedIn is almost as ubiquitous as Facebook and YouTube. As with Facebook, you can set up a business site or even a private compliance group for your organization. Your employees are the best place to start adding followers, as they are not only your target audience but they are also your biggest advocates. You can encourage employees to add their compliance profile to their personal profiles. By doing so, they automatically become followers and can like, comment on, and share your company updates to help expand your viral reach. As with Facebook, LinkedIn provides you a platform to communicate with your employee base. It has a chat function that can be used to solicit feedback and comments going forward. You can also tie in with or ‘link to’ other groups and people that can facilitate not only creating but also expanding your culture of compliance.

Twitter

Earlier this week, I wrote about how you can use Twitter to capture information from the marketplace of ideas. However Twitter can also be used for communicating with your employee base. Tweets are publicly visible by default, but senders can restrict message delivery to just their followers. Users can tweet via the Twitter website, compatible external applications or by Short Message Service (SMS) available in certain countries. Retweeting is when users forward a tweet via Twitter. Both tweets and retweets can be tracked to see which ones are most popular. Finally, through the use of hashtags (#) users can group posts to Twitter together by topic.

I believe that Twitter is one of the most powerful tools (and completely underused tools) that is available to the compliance function. If employees follow their company’s name through a hashtag, they can see what trending topics other employees are discussing. Compliance practitioners can help lead that internal discussion through the same technique. Moreover, if the Chief Compliance Officer (CCO) or compliance function regularly monitors Twitter they can keep abreast of any communications and those can be used as a backup communication channel, in case the company hotline or other reporting system is not immediately available or even convenient.

Meerkat and Periscope

Two of the newest and perhaps coolest tools a CCO or compliance practitioner can utilize in the realm of social media are Meerkat and Periscope. Both tools allow you to tell a compliance story in real time, throughout your organization and beyond through the capture and broadcast of video, live through your smartphone. They are both live streaming apps that enable you to create a video and open the portal to anyone who wants to use it. Anybody in your Twitter community can click on that link and watch whatever you’re showing on your phone. The big piece is the mobile aspect. It is as simple as a basic tweet and hitting the “stream” button.

This is one of the more exciting new social media tools I see for the compliance practitioner. You could start a compliance campaign along the lines a campaign that the company Hootsuite initiated called “Follow the Sun” using Periscope. They decided to let their employees showcase what they called #HootsuiteLife. They gave access to different people in every company office around the globe. Throughout the day, it would “Follow the Sun,” and people in different offices would log into the Hootsuite account and walk around and show off their culture, interviewing their friends, etc. They talk about the importance of culture and now they are proving it. The number of inbound applications drastically increased after people got that sneak peek into their company. You could do the same for your worldwide compliance team.

You can live stream video training around the globe. Moreover, if you use either of these tools in conjunction with internal podcasting or other messaging you can create those all important “Compliance Reminders” which were so prominently mentioned in the Morgan Stanley Foreign Corrupt Practices Act (FCPA) Declination. The videos that you create with both of these tools can be saved and stored so a record of what you have created can be documented going forward.

Pinterest

According to Pinterest for Dummies, this tool is an online bulletin board, a visual take on the social bookmarking site, where the content shared is driven entirely by visuals. In fact, you cannot share something on Pinterest unless an image is involved. When you share something on Pinterest, each bookmark is called a pin. When you share someone else’s pin, it’s called a repin. Your group pins together by topic onto various boards, aka pinboards, in your profile. Each board mimics a real-life pinboard. You can share images you find online, or you can directly upload images. Using the “Pin It” button, you can share directly in your browser from any web page. You can also share your pins on Twitter and Facebook.

Although a relatively new social media tool, I find it to be one of the more interesting ones for use by the compliance function as it compliments many of the other tools I discussed above. You can set up your compliance account for your organization and pin items, lists, or other visual information that can be viewed and used by employees. In addition to the enumerated items, you can pin such things as a link, a website, graphics or other forms of information. If you think of it as an online bulletin board, you can consider all of the compliance information that you can post for your customer base and the interactions they can have back with you.

All of these tools can help you as CCO or a compliance practitioner to engage with your customer base. On Monday, I will conclude with some final thoughts on why the compliance function should use social media tools available to them.

Once again please remember that I am compiling a list of questions that you would like to be explored or answered on the use of social media in your compliance program. So if you have any questions email them to me, at tfox@tfoxlaw.com, and I will answer them within the next couple of weeks in my next Mailbag Episode on my podcast, the FCPA Compliance and Ethics Report.

 

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

 

© Thomas R. Fox, 2015