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Memo to Managers
Let’s Talk Policies: Access and Education Make the Difference
One of your subordinates comes to you to ask if she is permitted to keep a gift from a customer. How do you know you are giving her the right answer? You certified that you read our code of conduct and our gifts and entertainment policies but, with everything you are asked to keep track of, how accurate is your memory?
Our policies (including our code of conduct) are important tools for managing the business risks they address. They set the behavioral standards for all our staff members, but they are only good controls if employees consult the policies when faced with a pertinent issue, and act according to the guidance. As a manager, you have two important responsibilities related to our organization’s policies–ensuring access and use.
Does your staff know where to find our policies and how to use them? You and your staff are responsible for complying with all company policies, and being able to access them when necessary is the first step. Here are some tips to help:
- Make sure employees know where our policies are stored and how to access them. And don’t just tell them. You need to show them.
- If you see that a policy is dated three or more years ago, tell the person responsible for maintaining it (or ask your boss or the compliance department, if you do not know who is responsible). Ask your employees to do the same. Outdated policies can get us into trouble just as fast as no policy at all.
- If you think our policies should be organized in a better way to enable access and use, let the compliance department know, because poor accessibility is an organizational risk. Controls do no good if you cannot get to them when needed.
One reason employees do the wrong thing is because of a lack of awareness and/or full understanding of our policy or procedure. As a manager, it falls to you to make sure they understand the types of risks and problems they may face in their jobs and how they are expected to behave. That means they need education on where to find the related policies, but also on how to apply the standards. Consider these ideas for educating your staff:
- When employees bring issues or concerns to your attention, first consult all the relevant policies and/or procedures together with the employee so that your staff gets used to consulting policies first for guidance.
- If you have an electronic policy management system, demonstrate its features to your staff. You may be able to link to training, the code of conduct and other supporting documents straight from the policies.
- During staff meetings, bring up a business risk your employees are likely to encounter. Give them a potential scenario and ask how they would handle it. This is a perfect time to show them the related policy and explain the parts that apply to the scenario.
Employees generally want to do the right thing. It is part of your job to make sure they have access to and know how to use all the important tools that are available to support their efforts. Our organization’s policies and procedures are some of those tools and should be referenced and brought forward to encourage continued use. This helps to protect our stakeholders, our coworkers and our organization.
Questions of the Month
Q. One of my employees has complained that our code of conduct is too expansive for them to remember. What can I do to help assist them in that effort?
A. You can cover critical issues within the code on a regular basis. Make it an ongoing segment of a team meeting, give them potential scenarios to discuss as a group or provide context for the policies as they apply to your work group. They are much more likely to remember and abide by our policies if they are brought into a real world context and reminded of them more than once yearly.
Q. I discovered that my employee was working a side job with a competitor. He said he did not know it was a conflict of interest that should have internally been disclosed. We have a policy on this, but can I discipline him if he really did not know?
A. The answer depends on whether or not he was informed of his responsibility to comply with the policy first. During our onboarding process, we share our code of conduct, which contains our conflicts of interest standard. And annually, exempt employees complete our attestation on conflicts of interest. Both activities involve employee attestation that they understand the requirements. In your situation, you should contact the compliance department to find out if the pertinent certifications were completed by the employee. If he certified that he would comply with the code and the policies, but did not, he cannot say he did not know about conflicts of interest. The code would have made him aware of what constitutes such a conflict and he could consult the code or other policy for remedial steps before taking the side job. If these are the facts in your situation, you have the right and responsibility to take disciplinary action.
Organizations that approach policy management strategically and exercise ruthless discipline with respect to their policies yield massive returns in organizational alignment, corporate culture, and ultimately their bottom-line results.
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