How do you know your compliance program is working, both for your peace of mind or if the government comes knocking? It’s a tough question, and many wonder either how to start measuring or if they’re measuring the right thing.
Andrew McBride, Founder & Chief Executive Officer at Integrity Bridge, has a great deal of experience in this area from his time serving as Chief Compliance Officer at Albemarle. In the wake of an FCPA scandal, the company had to be able to demonstrate the strength and See more +
How do you know your compliance program is working, both for your peace of mind or if the government comes knocking? It’s a tough question, and many wonder either how to start measuring or if they’re measuring the right thing.
Andrew McBride, Founder & Chief Executive Officer at Integrity Bridge, has a great deal of experience in this area from his time serving as Chief Compliance Officer at Albemarle. In the wake of an FCPA scandal, the company had to be able to demonstrate the strength and effectiveness of its efforts.
In this podcast he advises you remember three key questions from the US Department of Justice’s compliance program evaluation criteria: Is the program well designed? Is it applied earnestly and in good faith? Is it working?
At the same time, though, he cautions not to just seek simple metrics alone. It’s important to also track why you are measuring what you are measuring. Compliance teams need to take the time to build out the supporting narratives that explain why and how their choices were made and have a fully written out risk assessment. These documents help guide what is measured and establish why those measurements are worth taking.
Having the narrative in place also helps the program keep its focus. Over time people change and memories fade as to why a given compliance path was taken. With strong documentation of the original thinking, the compliance team can better assess if the program is delivering what it needs to or if it needs adjustment.
When it comes to who does the analysis of the data, he highly recommends hiring a data analyst. These individuals have the capacity to turn the numbers into meaningful dashboards and graphics that everyone can understand. They can also be adept at finding data where you might not think to look.
Listen in to learn more about how to effectively measure the effectiveness of your measurement efforts. See less -
