Y-Comply, a compliance and ethics newsletter from the SCCE
Y-Comply is intended to help communicate the value and purpose of compliance and ethics to the general workforce. You are free to copy this article to your organization’s website or electronically distribute it to your workforce; no attribution to either SCCE or the article’s original author is necessary.
written by Deann Baker, CHC, CCEP, CHRC
The last Y-Comply outlined all of the elements of an effective compliance and ethics program as defined by the Federal Sentencing Guidelines (FSG). Over the course of the next year, each of those elements will be covered more specifically. The element known as “Governance and high-level oversight” will be covered this time.
The FSG states that an organization’s governing authority shall be knowledgeable about the content of the compliance and ethics (C&E) program and exercise reasonable oversight with respect to the implementation and effectiveness of the program. This is the role of an organization’s board of directors. The FSG further states that a specific individual within the organization will be delegated the operational responsibility for the C&E program and report periodically on the effectiveness of the program to high-level personnel and, as appropriate, to the governing authority (board of directors) or a subgroup of the governing authority.
Essentially, the FSG is saying that the C&E program must be supported and led by the organization’s leadership. Rather than focus on the board’s role, the focus will be on how the compliance officer can best achieve implementation of an effective C&E program with management’s support. The most effective way an organization can weave compliance and ethics into its fabric is to prioritize the work, as it does with other projects and programs, and that is through the strategic plan. Those plans have defined goals that have to be measured, reported on, and met within a timeframe. The intent of the strategic plan and goals is to help the organization fulfill its mission, achieve growth, and/or improve results. Individual(s) on the management team are typically responsible for driving the goals, and they are evaluated by how well they performed and met or didn’t meet those goals. Some of the goals will be assigned to workforce members at every level of the organization, and they too are evaluated on how well they met the performance expectations.
The C&E program has to be developed in a very similar way to help make it important to the organization and its entire workforce. When goals are established and people are evaluated on meeting those goals, it becomes important. There is a saying “What gets measured, gets done” and this is true of compliance and ethics too. Each of the C&E elements can be measured, and performance goals can be established to evaluate the results.
Although management is typically identified as those who drive results and management is whom we think of as the leadership within the organization, we can all be leaders and drive results. If someone is able to help influence results by helping others achieve a goal, then they are a leader. We can all take the initiative to influence others, achieve results to help grow or improve programs and systems within an organization, and challenge poor or wrong behaviors. Being a leader is not just about a position or power. It is about how we influence others to help achieve goals in a right way.