Follow these steps to ensure a good culture thrives in your organisation
- Proper reporting lines should allow compliance to filter through all management levels – up and down. A direct reporting line from the compliance officer to the CEO/the board affects how seriously the rest of the organisation takes compliance.
- Middle management should be challenged on how compliance is actually being effected and implemented within the organisation.
- Policies should be as short as possible but most of all clear so that all levels of employees understand the message.
- Practices should be adapted for local jurisdictions so they are culturally and legally sensitive to the unique aspects of that region without compromising the overall message.
- Employment/training of ‘local champions’ – individuals within different jurisdictions who are trained and reiterate the importance of global compliance initiatives. In turn this multiplies the capability of key individuals within the organisation.
- Active whistleblowing mechanisms should be adopted.
- Consider ‘human thermometers’ – information should come from a range of sources at all levels of the organisation to detect signs of problems, threats and risks.
- Wider initiatives that could be implemented include: compliance training tailored for specific roles in the company, incentivising compliance through the bonus system (in contrast to sales targets alone) and using an independent firm to stress test compliance programmes.
Read Hogan Lovells' full article, Profit vs Compliance
Liam Naidoo is a Counsel and Khushaal Ved is a Trainee at Hogan Lovells