Lessons from Compliance & Ethics Week, 2015

By Cheryl Gilbert, CCEP, CIPP/US, CIPM
cheryl.gilbert@integramed.com

“What is it?”  – Comment from a company survey on employee’s views of the compliance program (October, 2014)

“I think what is being done to keep the ethics of [the company] in the forefront of peoples’ minds is refreshing.” Employee Comment (November, 2015)

In one year, we re-built our Compliance Program from the ground up—or minimally gained some traction. We started with a baseline survey of employees of their views on integrity, presented to the Board of Directors a plan for implementing a revitalized program, educated senior management on “tone at the top”, created a cross-functional Ethics & Compliance Committee, updated our Code of Conduct and started a risk assessment. With the basic bones in place, we culminated the year with an all-out Compliance & Ethics Week awareness event.

We knew that the keys to getting engagement from employees were going to be: fun, brevity and swag. We also had to do this on a shoestring budget with minimal staff.  Each day of the week, an email went out to all employees with a compliance quote of the day and/or a fun fact, a list of the daily events, entry links and deadlines.  Because the messaging was done with a sense of humor, after a couple of days employees looked forward to it!

Activities included:

• A Question of the day, with a random winner selected  daily and the opportunity to win a grand prize if an employee answered the question correctly on all five days.  The answers to the compliance-related questions were discussed in the next day’s email, which was a great opportunity to educate. For example, many people may have had the same wrong answer to a question, but we had the forum to correct and inform in an immediate and memorable manner.
• Several daily puzzles. One day it was a word search, featuring Code of Conduct terms and created using a free program found on the web, which was surprisingly one of the employees’ favorite activities of the week. Other days featured an acronym quiz, a haiku writing contest (with our shared values as the theme) and a Code of Conduct scavenger hunt (the least popular activity).
• An essay contest with the theme of “the company shared value that means the most to me” and a prize of a $250 gift card. We had more than two dozen entries for this. Between the essay contest and the haikus that were submitted, we have much good material to leverage in our Compliance Program collateral materials. The essays in particular were thoughtful and heartfelt, and the panel of judges had their work cut out for them.
• Locally in the home office, we designated Wednesday for some special activities that we could not roll out to the entire field.  We offered “Breakfast with a Dash of Compliance” (put out food and they will come!). We started with a short video from our President, who was unable to attend in person, and then showed short, fun videos with an ethics theme (clips from Dilbert and “The Office”, both found on YouTube). In between showings, we had an informal Q&A with attendees.

At the end of the week, the feedback we received about the week’s events were, across the board, positive: “It was a great week of getting to know about ethics and compliance while having fun and some laughs too”; “Love that ‘fun’ was included in the learning/review process.”; and “It would be great if ethics and compliance day was a national holiday!”

If you are considering running an awareness event, here are a few tips:

• Keep the prizes simple.  Gift cards can be ordered and delivered online in any denomination. We were also able to obtain prize items from other departments who had excess promotional items (such as HR and Marketing). Our prizes included Amazon and Starbucks gift cards and merchandise emblazoned with the company logo (polo shirts, towels, badge holders, and USB charging sticks).
• Use a survey platform for employees to submit their contest answers online (we used Grapevine) which makes entering and picking random winners easy. Give specific entry deadlines. On the last day of the week, the daily entry form included space for employees to comment on the week’s activities, and this is where we received a large amount of rave reviews and other feedback.
• If not using a survey platform, create a specific electronic mailbox for employees to communicate with the Compliance Department, such as IAmComplaint@companyname.com.
• Keep a binder with all of your entry forms, rules, daily emails, prizes, winner, notes and related information. The value of having it all in one place will be immeasurable!
• When doing a skill contest such as an essay or poem, have the employees sign a release upon entry giving the company the right to use the material submitted for promoting the compliance program.
• Take advantage of all the opportunities for messaging, be it the daily emails, notes in the prizes sent to winners, the online survey platform entry forms—wherever!
• Repetition is the name of the game. During the week the link to the compliance intranet page was referred to no less than 10 times!
• Activities such as an essay contest may require more than a week to get people to participate.  We sent out a “coming soon” email about Compliance & Ethics Week two weeks before the event started and announced the essay contest then, with another reminder the following week, and then daily during the event.
• Don’t bite off more than you can chew. One event we considered was a company-wide virtual breakfast (via GOTO Meeting) but the logistics got complicated due to the number of employees and remote locations, so it was tabled.

Cheryl Gilbert,  CCEP, CIPP/US, CIPM, is the Privacy & Compliance Officer for a medical practice management company.