This client is a multinational company operating in over 80 countries.
The feedback from the business was that compliance was not always an enabler: the staff found compliance hard to understand, there were varying degrees of compliance, and some business groups simply did not implement the required programmes. There were many mixed views of compliance from the business groups across different regions which created a great deal of misunderstandings.
We worked with the client to build a set of Integrity Circles®, which were small group sessions of ten to 15 people. There were two to three sessions held in each country, depending on the size of the business in the area. A vast array of people attended the sessions from all facets of the business.
The attendees were asked to join in on one of the Integrity Circles® at a suitable time. In some cases, we reorganised attendees to make sure the groups were well balanced. We also made sure that there were no senior managers so no one would feel intimidated - we organised a separate session for them.
All of the sessions broadly followed the same agenda. They were not training sessions, although there was an element of awareness for training. The sessions were designed to:
- Introduce the compliance programme to many people for the first time and show them our focus
- Obtain feedback on the compliance programme generally and identify major risks
- Gain an understanding of the local issues that existed in the market in terms of compliance (e.g. special local laws that impacted the overall programme)
- Gauge where the company was positioned in terms of compliance against peers
- Test the whistleblower programme and ensure that people were aware of it.
- These sessions were not an audit; they were engaging, open-discussion forums. PowerPoint was rarely used and the group led the discussion unaided.
About two months in total. Each in-country session took two to three days, depending on the size of the operation.
Why The Red Flag Group?
Practical. We are practical and engaging in our sessions. We know how to make people feel at ease and how to engage non-compliance people to talk about compliance.
Country and regional experiences. With worldwide knowledge and expertise, we know the history and current issues of countries; which allows us to probe for the correct information and ask the right questions while remaining culturally sensitive.
Logistical Management. We arrange and manage operations in various locations from start to end. While providing you with the necessary support to carry out primary activities.
Recommendations. No one wants just a list of issues, they want to hear recommendations and see them acted upon. This is what we provide in every situation we engage in.
- Designing the Integrity Circles® and setting up the session objectives
- Drafting the agendas and arranging locations in our offices or the client offices
- Attending and facilitating all sessions in country in multiple languages
- Drafting a report for management on summarizing concerns identified
- Drafting a gap analysis and areas for improvement across the entire compliance program report out to all participants
- Integrity Circles®
- Whistleblower programme review