By Kristy Grant-Hart
Several months ago, I put out a survey to the compliance community asking people to tell me their number one planning and strategy question. I wasn’t surprised to find out that all of us had variations on the same questions, such as “How do I obtain buy-in for my program?”, “How do I prioritize risks?” and “Where do I start?!?”
Effective strategy and planning is the critical differentiator between highly effective compliance professionals and those who work hard fighting fires, but never seem to accomplish what they are capable of. The suffering of those who work incredibly hard but haven’t employed strategy led me to develop my book and course, the Wildly STRATEGIC Compliance Officer Workbook. Following find five simple ways to be a wildly strategic compliance officer.
- Create a Plan and Commit it to Writing
If you have the best of intentions, but you haven’t written down what you expect to accomplish, it’s easy to get sidetracked. Maybe you started the year committed to updating your company’s Code of Conduct and implementing sanctions screening software, but now it’s May and you’ve been so busy performing internal investigations and dealing with a data breach that you haven’t started on the Code. When things calm down, it’s easy to forget what you’d committed to originally, or to spread your energy on three or four projects, none of which get completed. Writing down your plan and goals will help you to stay focused when things get crazy.
- Get Buy-In On Your Vision BEFORE You Start
Your major stake-holders need to know your vision for your compliance program. Once you’ve got your plan down in writing, present it to the Board or C-suite, and ask for feedback on it, before you begin implementation. This is critical because your ideas of what is most important may not correspond with the Board, C-Suite or other management’s ideas of what is most important. If you set about implementing your plan before obtaining agreement on the goals with your stakeholders, you may be creating something they don’t like or want.
- Align Your Vision to the Business Objectives As Much As Possible
When you present your plan, you want to show the business the ways in which it supports the greater business objectives, while still mitigating risk and responding to regulatory obligations. Let’s say your business is moving away from physical products to offer more online services. You can take a strong focus on data privacy and security as part of your annual objectives to support the digital strategy. Perhaps your business has acquired another company that it needs to integrate into the main business. Your objectives could include doing compliance training and helping them to incorporate your compliance procedures so the company can integrate more easily. By showing the business you’re interested in helping to move their objectives forward, you will be perceived as being on the business team.
- Ask for Budget and Resources AFTER Your Plan is Approved
It is nearly impossible to ask for resources to fulfill your vision if your vision hasn’t been approved by your stakeholders. Once you’ve socialized your plan and your stakeholders have agreed to the vision, you can then ask for the specific monetary and employee resources which will allow you to complete your vision. If the stakeholders like the vision but refuse to commit resources, you must either explain more explicitly and specifically why you need them, or change the vision to reflect the lack of those resources. Your stakeholders must understand that refusal to give resources means that you need to change the vision. Speaking of…
- If You Have Too Many Fires, Change the Plan
If you do everything correctly and begin implementing your plan, but then get slammed with a regulatory investigation or large-scale data breach, you may need to change the plan. Be proactive. If you see that you will not be able to accomplish one of your goals because you’re suddenly embroiled in an international investigation, go to your stakeholders and tell them how the plan and goals have changed. By proactively telling them that there is a problem, you’ll allow them to reframe their vision of the program with you, so that at the end of the year you can still deliver on their expectations.
Strategy and planning make the difference between simply getting by in your job and being an in-demand business asset. By making a written plan, getting buy-in for your vision and executing on your goals, you will succeed at becoming a wildly strategic compliance officer.
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Kristy Grant-Hart is the author of the Wildly STRATEGIC Compliance Officer Workbook and online course. She’s the CEO of Spark Compliance Consulting, and Adjunct Professor at Delaware Law School, Widener University, teaching Global Compliance and Ethics. Prior to launching Spark Compliance, she was the Chief Compliance Officer at United International Pictures, the joint distribution company of Paramount Pictures and Universal Pictures in 65+ countries.