Good compliance programs are premised on tasks and checklists. Great compliance programs are premised on culture.
It’s Like Sitting Around a Campfire
Imagine a camper sitting around a fire where there is a small, ever-changing breeze. The smoke from the fire continuously changes direction and the camper moves their chair to avoid the smoke, thinking that the smoke will not flow in their new location. The camper usually ends up moving the chair several times as they keep trying to avoid the smoke. Today’s regulatory environment is like a campfire, continuously moving with changes like the breeze. Just like the camper is reactive, so are many good compliance programs in business today. As regulations shift through legislation or other various initiatives, compliance officers sharpen their pencils and make changes to their compliance management systems, checklists, standard operating procedures and the like. Instead of moving chairs, they move processes to avoid the smoke.
Great compliance programs focus on the structure of the fire pit instead. Reconstruction of a fire pit can reduce the smoke’s affect of the camper as the small breeze changes direction. Where compliance programs evolve from good to great, they shift their focus and concentrate on the culture of the company instead. With this approach, each shift in legislation or other initiatives calls for less dramatic changes in company policies and procedures.
The Key to a Successful Compliance Program
Compliance at times feels like a checklist. Have all the “i’s” been dotted and the “t’s” been crossed. While that is an important task within a successful compliance program, it is not where you should focus.
In our continuously changing regulatory environment, the key to successful compliance programs begin with an honest analysis of your company culture, directing your energy and focus on the foundation and less time with the winds of change. Where corporate culture and compliance are aligned, you will find great compliance programs. It starts at the top and ends nowhere.