We asked industry experts, colleagues and compliance officers what they believe will be the top issues impacting workplace ethics and corporate compliance programs in 2015. We gathered their best thinking and prepared our annual summary of trending issues and the steps you should consider taking as you plan for the coming year. We’ll share each of the trends here over the next few weeks
By every indication we are about to witness a dramatic leap in technology-enabled ethics and compliance.
Tech Advancement in Key E&C Areas
Trends and our own client experiences are demonstrating that we are likely to see advances in each of the following areas:
1) Codes of Conduct
Last year we saw a significant increase in the number of organizations considering ways to better use technology to revamp how they develop, design and distribute their codes of conduct and manage associated policies. The driving force in code improvements was recognition that the code is primarily a communication and reference tool for employees.
With that in mind, enhancing the ease of use, readability and access to information becomes a priority. In that light, lengthy, wordy codes that repeat what is already in policies and employee handbooks are understood to be counterproductive. And so, to enhance usability, organizations are exploring ways to create web-based versions of their codes and/or adding technology features to codes including embedded video, and links to FAQs and to more in-depth policies.
2) Policy Management
Even more progress is occurring on the policy management front. Policy management tools are now available to significantly streamline what is too often a manual process. Maintaining updated policies and documenting and tracking their delivery—as well as linking policy information to training and helpline data—can greatly improve ethics and compliance efficiency. This is a step that compliance officers should include on their to-do list for 2015.
Along with the development, management and distribution of codes and policies, training is also undergoing a transformation added by advances in technology. Employees are sophisticated consumers of technology and they expect on-line training to meet their standards. Fortunately, new formats and short, burst learning vignettes (also called micro learning courses) are proving to be very effective, not only for general training but also for targeted training on specific risk topics and audiences—particularly senior executives, boards and third parties.
Watch a preview of our Workplace Harassment training course to see an example of a cutting-edge, tech-enabled approach to eLearning.
4) Third Party Risk Management
As we have noted in past annual reviews, third party risk is still the “Achilles’ heel” for many organizations. Companies with global supply and distribution networks are especially at risk. Unfortunately, many organizations are inconsistent in their application of standards or they rely on manual processes that are time consuming, difficult to audit and lack the ability to be benchmarked for industry comparisons.
In 2015, we expect to see a continuation in the number of organizations that are automating their third party risk management process. The benefits of doing so are clear. An automated third party risk management system can:
- Help identify your universe of third-party relationships and prioritize it by risk.
- Conduct due diligence on a risk-adjusted basis and uncover and assess risks that require additional attention.
- Clarify, communicate and document mitigate steps that are required to address risks that are uncovered.
- Assist in continually monitoring and periodically re-screening third parties to flag risk-related changes that may occur, and to ensure follow through that mitigation steps are occurring.
- Provide an auditable documentation trail.
Leveraging Big Data and Predictive Analytics in E&C
Ethics and compliance programs gather a huge amount of information from a variety of sources including helpline and case management reports, surveys, training records, code attestations, program audits and assessments, regulatory actions, financial performance and more.
This data can serve as the “canary in the coal mine,” an early warning system that trouble is brewing. And further, the data can provide a diagnostic measure to help you identify where steps can be taken and how to better deploy your assets to improve your organizational culture and the effectiveness of your ethics and compliance efforts.
It’s worth noting that other departments in your organization (such as sales and marketing) are probably already using big data to understand their customers and assign resources. It won’t be long before compliance officers can tap into the power of the total data available in their cross-organizational systems. But we aren’t quite there yet.
In E&C, we still tend to look at (and share) our data only at a high-level summary rather than conducting a deeper, more granular trend analysis. Therefore, we are more reactive than predictive. And, ethics and compliance faces a lot of fragmentation. Some of our most powerful data sources (HR, financial reporting and quality systems) are not yet connected to us.
Though we haven’t fully pulled together all of our relevant data sources, that doesn’t mean we can’t do more with the data we have. And, at the same time, we can take steps toward laying the groundwork for a more robust data mining and predictive capability.
Key Steps to Better Leverage E&C Data
- Begin integrating data from multiple departments. Consolidate helpline, open-door, mobile and web based incident reports into a single location for secure review, investigation, resolution, reporting and analysis.
- Allow multiple departments to manage cases and roll up for data analytics to provide more comprehensive insights across the organization.
- Learn from your ethics and compliance training and learning management systems (LMS), including drilling down into information pertaining to specific employee populations and risk areas. The findings can help you gauge whether training is effective and whether additional targeted efforts may be needed.
- Learn from your hotline/helpline data. Look for trends and red flags related to:
- Types of reports/call categories
- Allegations versus inquiries
- Anonymous versus named reporters
- Sources and allegation types by groups, locations, businesses or services
- Substantiation rates, for both named and anonymous reports
- Discipline/remediation actions
- Case cycle time
- The number of online vs. telephone reports
- Follow-up contacts from anonymous calls