[authors: Ahmed Salim and Walter Johnson*]
CEP Magazine (January 2025)
In recent years, diversity, equity, and inclusion (DEI) have gained heightened attention as organizations recognize the moral and business imperatives behind fostering diverse work environments. This shift is not only a response to growing social movements advocating for equality but also to the tangible business benefits organizations can reap. Studies have shown that companies with diverse teams tend to outperform their competitors in terms of innovation, decision-making, and financial returns.[1] Compliance professionals are at the forefront of this transformation, acting as both gatekeepers and champions of ethical, inclusive practices. By integrating DEI into compliance strategies, organizations can ensure that their policies promote fairness and prevent discrimination, ultimately leading to a more robust organizational culture.
In September 2020, the Society of Corporate Compliance and Ethics & Health Care Compliance Association (SCCE & HCCA) established a working group to explore ways to support DEI initiatives within their organizations. This effort led to the inclusion of DEI topics in conferences, articles, surveys, roundtable discussions, and the development of member resources. By October 2022, compliance professionals gathered at the Compliance & Ethics Institute to discuss practical methods for implementing and championing DEI initiatives. Various perspectives were discussed, such as the compliance officer serving in a dual role as the DEI officer, the compliance officer collaborating with human resources and/or other senior leaders, and the compliance officer attempting to champion DEI in their program. These discussions focused on the opportunities and challenges faced by programs with varying levels of leadership and financial support and culminated in SCCE’s Diversity, Equity, & Inclusion Considerations for Compliance Professionals.[2]
Resource contains guidelines and strategies
The comprehensive resource emphasizes the importance of incorporating DEI into organizational culture, highlighting that the progression of organizations and the communities they serve depends on valuing diverse voices. The working group, co-chaired by SCCE co-founder Odell Guyton and SCCE & HCCA immediate past president Walter Johnson, along with numerous contributors, developed a set of guidelines and strategies for compliance professionals. These include securing top leadership’s commitment to the DEI program, forming cross-functional DEI committees, and involving employees at all levels in shaping inclusive initiatives. The resource stresses that DEI should be treated as a business strategy, not just a human resources initiative, and should be led by senior organizational leaders.
To establish an effective program, organizations must define core values and behaviors that reflect their commitment to DEI. This involves looking beyond protected classes and broadening the scope to foster openness and inclusion. Organizations should conduct thorough assessments of their current culture and practices to identify gaps and areas for improvement. Setting clear goals, measuring progress, and providing the necessary resources are crucial for the success of DEI initiatives. Policies should be reviewed to ensure they are inclusive, written in plain language, and free from potentially exclusive terms and stereotypes.
Monitoring and accountability are key components of successful DEI programs. Organizations should start with an honest culture assessment and identify key performance indicators to monitor progress. This includes evaluating the diversity of candidate attraction, hiring, and retention, as well as analyzing salary and promotion patterns for equity. Transparency in reporting DEI metrics to employees is essential, and holding C-suite executives accountable by incorporating DEI into performance evaluations and compensation can drive meaningful change. Training on unconscious bias and workplace civility is also recommended to increase self-awareness and promote inclusive practices.
Compliance and ethics play a vital role in DEI initiatives. Frontline managers should receive training on handling and escalating complaints, and DEI concepts should be integrated into compliance and ethics communications. Encouraging employees to speak up about diversity issues and ensuring that investigators are appropriately trained and familiar with local cultures are important steps. Managers have a crucial role in building an inclusive work environment by recognizing and mitigating their biases, promoting open communication, and supporting diverse individuals in decision-making roles. Social gatherings and team activities should be inclusive, catering to various dietary requirements and preferences to ensure everyone’s comfort.
Collaboration between compliance professionals and other departments, such as human resources and legal, is essential for fostering an effective DEI culture. While human resources may focus on recruitment and retention efforts, compliance officers ensure that these initiatives are aligned with ethical standards and legal requirements. For example, a compliance officer might collaborate with human resources to develop training programs that address unconscious bias while ensuring they comply with anti-discrimination laws. Legal teams can also work closely with compliance professionals to navigate the complex regulatory landscape surrounding DEI, particularly when dealing with sensitive data related to race, gender, and other protected categories. In this way, compliance professionals serve as the backbone of DEI efforts, ensuring they are not only aspirational but actionable and compliant with applicable laws.
Steps to building a more effective program
Compliance professionals can use this information to build a more effective DEI program in several ways. First, they can start by conducting an honest culture assessment within their organization. This involves evaluating the current state of DEI in the organization to identify gaps and areas for improvement. This assessment can be done through surveys, interviews, or focus groups. The assessment can be developed in-house, or there are templates available online that can be modified.
Second, compliance professionals can establish clear DEI goals and objectives. These goals should be specific, measurable, achievable, relevant, and time-bound—SMART. They should also be aligned with the organization’s mission and vision statements and overall strategic objectives. This alignment contributes to an easier adoption across the organization.
Third, compliance professionals can ensure that DEI considerations are incorporated into all aspects of the organization’s operations. This includes recruitment and hiring practices, procurement processes, and even the way the organization conducts exit interviews. For instance, they can design strategies for attracting a more diverse pool of applicants for positions and create an equitable procurement process that overcomes barriers for minority businesses.
Fourth, compliance professionals can hold both executives and employees accountable for DEI. This can be done by incorporating DEI into performance evaluations and compensation. For example, they can assess executive team diversification efforts and ensure that diverse viewpoints are considered in discussions.
Fifth, compliance professionals can provide training and development opportunities related to DEI. This can include training on unconscious bias, workplace civility, and the importance of DEI. They can also promote professional development forums, initiatives, and events that enhance DEI. They can also review and update existing general training to incorporate images and content that support DEI initiatives.
Finally, compliance professionals can ensure transparency in their DEI efforts by regularly reporting on the progress of their initiatives. This can be done through internal updates, newsletters, annual reports, or even the organization’s website.
Conclusion
Compliance professionals can play a crucial role in promoting diversity, equity, and inclusion within their organizations. To establish a sustainable program, organizations must define their core values and behaviors. Leadership must demonstrate their commitment in their daily activities for management to adopt and employees to embrace. Although this requires tremendous effort from all parties involved, it can be accomplished in five steps.
Takeaways
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SCCE & HCCA established a working group to assist the association in developing resources and creating programming content.
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After a facilitated diversity, equity, and inclusion (DEI) discussion, the association developed a resource to assist compliance professionals with implementing and/or contributing to DEI initiatives at their organization.
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The compliance department plays a vital role in DEI initiatives, whether they lead or champion these efforts.
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Several factors such as core values and behavior contribute to an effective program.
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There are five steps to consider when implementing an effective DEI program.
*Ahmed Salim is an Adjunct Professor at DePaul Law’s Jaharis Law Institute and the Chief Compliance Officer at a professional services firm in Chicago Illinois, USA., and Walter Johnson is Assistant Privacy Officer at Inova in Falls Church, Virginia, USA.
1 NLI Staff, “Why Diverse Teams Outperform Homogeneous Teams,” NeuroLeadership Institute, June 10, 2021, https://neuroleadership.com/your-brain-at-work/why-diverse-teams-outperform-homogeneous-teams.
2 Society of Corporate Compliance and Ethics & Health Care Compliance Association, Diversity, Equity, & Inclusion Considerations for Compliance Professionals, 2023, https://assets.corporatecompliance.org/Portals/1/PDF/Resources/scce-hcca-2023-diversity-equity-inclusion-considerations-for-compliance-professionals.pdf.
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