One Month to a More Effective Compliance Program in Training and Communications - Day 8 - One Using Communications to Drive a Speak Up Culture

Thomas Fox - Compliance Evangelist
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How often have you thought about the role of communications in your entire hotline reporting system? I do not mean posters giving the hotline number, promising anonymity and non-retaliation. I suggest using compliance communications to create a social environment where employees feel comfortable speaking up to ask questions and report concerns, and they know the options for doing that.

Why do many compliance professionals find it so See more +

How often have you thought about the role of communications in your entire hotline reporting system? I do not mean posters giving the hotline number, promising anonymity and non-retaliation. I suggest using compliance communications to create a social environment where employees feel comfortable speaking up to ask questions and report concerns, and they know the options for doing that.

Why do many compliance professionals find it so challenging to use compliance communications to help move the ball forward on driving a speak-up culture? It begins because many conflate such communications with training. Training tends to be viewed as something that happens once per year or on a similar cadence. Yet even the DOJ had seen through the fallacy of this argument in its 2020 Update to the Evaluation of Corporate Compliance Programs when it stated, “Companies have invested in shorter, more targeted training sessions to enable employees to timely identify and raise issues to appropriate compliance, internal audit, or other risk management functions.”

The 2020 Update also leads to the following questions, what resources have been available to employees to provide guidance relating to raising an issue? And, as your company assessed whether its employees know when to seek advice and whether they would be willing to speak up? Can you answer these to the satisfaction of the DOJ? If not, you may have a gap in your speak up communications program.

The bottom line is that you are only limited by your imagination in compliance. You can create something special when you overlay creativity with your imagination. And you can use compliance communications to drive a speak-up culture.

Three key takeaways:

1. How can communications improve a speak-up culture?

2. Use communications to foster trust.

3. A speak-up culture only works when paired with a ‘listen-up’ culture. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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