The Red Flag Group’s IntegrityCircles® | Compliance Reviews are casual focus groups led by experienced compliance people. They allow compliance issues and concerns to be raised by employees and partners in an informal environment, in small groups or in one-on-one sessions. Our facilitators can also provide insight on how different compliance issues are being addressed in peer companies. IntegrityCircles® are often conducted as break-out sessions from larger meetings, conferences or other events where multiple partners get together.
IntegrityCircles® | Compliance Reviews are a great way to obtain a “voice of the customer” regarding your compliance programme. From the people who use the programme everyday – your employees and partners – you can find out what the programme means, how it adds value (or doesn’t add value) and how it is seen by the management team around the world.
The following are ten things to think about before you hold IntegrityCircles® | Compliance Reviews.
1. Select your countries and regions carefully
For most large companies there will be a need to decide which countries, business units or regions should be the subject of the IntegrityCircles®. Consider selecting those which have had compliance issues, have been the subject of investigations or are higher risk. In addition, select some regions that have performed well in terms of compliance so that you can clearly see the difference. Most importantly, pick the regions that need the most support to be compliant and have the most business at risk if there is a compliance issue. You will also know from your own business those areas, business units or regions where there is more “noise” around compliance. Make sure these are included in the IntegrityCircles®.
2. Plan your locations, times and attendees
It may go without saying that planning the locations and times for the IntegrityCircles® | Compliance Reviews is important to ensure that people have sufficient time to register for their session. Normally you might have three or four sessions a day for 90 minutes each, preferably with ten to 15 people in each session. Logistically it is better to have one large conference table or have desks arranged in a large U shape. IntegrityCircles® | Compliance Reviews are meant to be an informal setting – not training – so conference-style seating is not advised.
3. Have separate management sessions
IntegrityCircles® | Compliance Reviews are meant to be informal and open. They are designed so people feel comfortable giving honest and open opinions about compliance and how it works in their company. The plan is to have people voice any frustrations that they may have about compliance and also perhaps provide their insight into some of the areas where they believe the company might be falling short. Because of this, it is not advisable to have any senior managers in the sessions as they tend to dominate and make people feel uncomfortable. Best practice for holding IntegrityCircles® is to have a separate session for management.
4. Draft an agenda and a short PowerPoint presentation
Some IntegrityCircles® work really well and people immediately open up; however, usually participants will need a stimulus of some sort. A good idea is to build a brief agenda before the meeting, even if it is fairly flexible – many senior employees will demand an agenda before accepting a meeting. Good practice for IntegrityCircles® is to also prepare a brief PowerPoint presentation for the session. Remember that it should not be a training presentation, but should be designed to explain the purpose and outcomes of the session. Keep it to five or six slides which will act as placeholders for discussion topics.
5. Think about some probing questions in advance
The sorts of open questions that you might ask are:
- Do people understand what compliance is?
- What do people think of the policies and procedures across the company?
- Is the training simple and easy to understand?
- What is the company culture around compliance? Do people really take it seriously or is there a “tick-the-box” mentality?
- Are there issues with reporting? How do people report? What is the culture regarding reporting issues?
- Does management “walk the walk” with compliance?
- How does your company compare to its peers?
- What is the competitive environment like, both externally and internally?
- Where are the areas that compliance could improve?
6. Select a facilitator
IntegrityCircles® | Compliance Reviews are facilitated sessions. In many cases the topics being discussed at the IntegrityCircles® are sensitive and people may feel uncomfortable talking about them. It is important to make everyone feel comfortable; ensure that all attendees remember that they are not being audited or reviewed so that they feel confident speaking their minds. For this reason it is essential to have a good facilitator. Someone needs to be able to keep the discussion going, ensure that everyone participates, make people feel at ease and, most importantly, ensure that the discussion is lively. The facilitator might also need to be trained on some of the risk areas of the business and have a solid understanding of the business and the existing compliance programme. Never underestimate the importance of having a strong facilitator.
7. Prepare your opening disclaimer language
The participants at the IntegrityCircles® | Compliance Reviews should be briefed at the start with some typical disclaimer language. The disclaimer might include comments around confidentiality, or perhaps discussions about legal requirements to investigate if allegations are made that the company has committed a crime. The participants will want to know whether the comments that they make in the session will be attributed directly to them in the post-discussion report, or whether the report will be generalised. This needs to be discussed at the outset.
8. Prepare some “takeaways”
At the end of IntegrityCircles® | Compliance Reviews, the participants will want to have some idea of what comes next. Be prepared to summarise the next steps, which are likely to include some idea of when a report will be issued to management and what that report will contain. There might be some summaries to hand out after the discussion, or perhaps a small gift to thank the participants (such as a compliance-branded souvenir).
9. Prepare a report for all participants
People have given their time to participate in the IntegrityCircles® | Compliance Reviews and will want to see the results of the sessions. Feedback shows that participants will be less willing to speak up in the future if they feel that their input has not been considered. They should be given a consolidated report of all sessions (which has been sanitised for very confidential matters). The IntegrityCircles® report should be sent as soon as possible after the end of the last session. The report should include specific actions that you will take given the feedback received. If people have reported any situations in the sessions they will want to know what the compliance team is doing about those situations and will be expecting improvements. They will also want to see whether the feedback they gave is consistent with that given in the other sessions.
10. Write a report for management
Management will have funded the IntegrityCircles® | Compliance Reviews and may have also participated in them, so they deserve to see the feedback from the sessions. You will need to draft a different version of the report than that which was written for the attendees, focusing on the more holistic issues that were raised in the sessions and looking at trends, steps forward and lessons learned from the sessions.