Use your (corporate) lungs in a best practice compliance programme

Tom Fox

If there is one thing that is ubiquitous in Venice it is the Gondola boatman, also known as the Gondolier. One is never far from hearing cries of “Gondola, Gondola” to attract tourists for a fabled and romantic gondola ride. To announce his offering, the Gondolier must have a stout pair of lungs and be in very good physical condition. They also need these attributes to be able to pilot this very old craft by hand in and around the crowded waters of Venice.

As a chief compliance officer (CCO), or compliance practitioner, the more that you can get out of the office, into the field and meet the troops, the more fit-for-purpose your compliance program will be. Any best practice compliance programme should have input from the geographies, cultures, business units and corporate functions within the company. For example, it is well understood that a compliance procedure that works well in the United States may not work in Indonesia.

This means that a CCO or compliance professional needs to understand how the cultures in their organisation work and then create a compliance programme to fit those needs. It does not mean that a company can continue to do business with corrupt intent. However, if there is a culture of gift giving in a specific geographical area, for example, you should determine a way to continue such courtesies within the context of your overall compliance regime.

The United States FCPA Guidance specifies that you should train your employee base on your compliance protocols in local languages. For certain countries, this could mean translating into more than one language. In Spain, for instance, you may be required to train both in Spanish and Catalan if you have operations in the Catalonian region.

Conversely, to make your compliance programme more robust, you should not simply believe your own story or, even worse, your own propaganda about the effectiveness of your compliance programme. Simply because a country manager says that something is true does not mean that it is true. You also have the opportunity to get out of the home office and visit international locations. This is the best way to find out what is going on in the field. In the compliance arena, your primary sources are the employees in your own organisation. So use the lungs and strength of your compliance programme to get the message of compliance out through your organisation.

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