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MEMO TO MANAGERS
Has Your Compliance Risk Profile Changed?
When’s the last time you took a few moments to do an ethics and compliance risk assessment on...yourself? Things in our organization can change quickly, including managers’ span of control, members of your team, which vendors we use and more. As your business partners, we in the ethics and compliance department want to be a resource for you when your exposure to ethics and compliance risk changes or expands.
So take a moment and review this list: do any of these sound familiar?
- Your span of control has increased, and you are now dealing with employees or third parties in countries you haven’t worked with before.
- You’ve started working with a new internal team.
- You’re dealing with fast-moving structural changes to your team or your department.
- A new law or regulation has come into effect and you’re not sure what the implications might be for your team.
- You have new team members from a generation or cultural heritage you’re not accustomed to working with.
- You’ve recently been promoted to a management position, and wish you had a better grasp on ethics and compliance issues that might come up in your new role.
- An employee brings a potential compliance violation to you and you aren’t sure how to respond.
- You’re not entirely clear on how to apply one of our new or updated policies—or a longstanding policy that now applies to you more directly.
Any and all of these issues (and many more like them!) can create new ethics and compliance challenges for managers. We want to remind you that you are not on your own! If you have questions about ethics and compliance concerns, we want to connect you with help. From one-on-one consultations, training resources and advice to setting up mentoring relationships with other managers within our organization, we are committed to equipping you for success.
Raising your hand when issues come up is a major part of owning ethics and compliance. There is no question too small to ask. Set an example for your team: “speak up” when you face new ethics and compliance challenges. Together, we’ll continue to build an ethical and compliant organizational culture we can all be proud of.
Questions of the Month
Q. I was recently promoted and am now working with third party vendors for the first time. In a recent interaction with a potential vendor, they offered me a “perk” if I picked them to work with. I said no thanks. Was that an attempt to bribe me? What should I do?
A: If it was not a bribe attempt, it sounds like it could be perceived as one. You were right to hesitate. Contact the ethics and compliance department and work together to determine what next steps should be. Particularly if the vendor has relationships in other parts of your organization, additional due diligence may need to be completed.
Q. My company recently acquired another company, and I’ll now be managing remote employees for the first time. From an ethics and compliance perspective, what are best practices for making sure remote employees are following our company’s code of conduct and policies?
A: A variety of approaches are important when your team includes remote employees. First of all, be sure to keep in touch with them regularly through video calls and phone—not just email. Pay close attention to ethics and compliance surveys or assessments that are completed in the location where your team member works: are there trends or issues that seem to be prevalent in the organizational culture in their office? Ask about those issues. It’s also important for you to “walk the walk”—both with on-site and remote employees. Make ethics and compliance issues a natural part of your team meetings and conversations—and make sure your team members know you are committed to a zero-retaliation policy; that they can always come to you with any questions or ethical dilemmas they have.
Do your employees see your policies as a necessary evil and an inconvenience? Or as a body of shared knowledge used to strengthen, support, and protect you organization? If perception of policies in your organization is not all it could be, consider ways to remind your stakeholders about the purpose of your policies.
Using Compliance Communicator
Equipping managers with the skills they need to navigate the E&C challenges they face is critical. Use the content in Compliance Communicator to help keep compliance top of mind with your managers and strengthen your organizational culture. NAVEX Global grants you permission to publish any or all of the content to best suit your needs.
For more valuable content from our Advisory Services team, subscribe to our blog, Ethics & Compliance Matters™. You’ll find perspectives on the latest E&C trends that impact your program, and get insights on increasing program effectiveness.