We just wrapped up our 9th Compliance Tech Talk, this time returning from the Twin Cities. We spoke with compliance, legal, investigation and audit professionals on the challenges they face in their compliance programs. From retail and medical device to construction and nonprofits, this roundtable hosted 17 attendees at the Marin Restaurant in downtown Minneapolis.
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1. Tell your board the story behind the numbers
Board reports traditionally have looked backward, analyzing what happened in the past. Typically, you stand in front of your board and share with them numbers around attestation rates, the amount of and which policies you updated, the number of calls your hotline receives every month or annually, etc. They seldom spark questions of substance from your board. Yet, if you tell a story with your data, it will provide the board with much more context to how that number came to be and what it really means for the compliance program, the company, and the bottom line.
If I went into a board meeting and just rattled off numbers without directly adding value to the information I chose to share, it would not be a very good meeting,” said Patrick Quinlan, CEO, Convercent. “You have to tell the stories of each number and tell those stories well so the board gets immediately hooked and engaged in what you’re trying to say.”
According to data software company Tableau, you should break the process of telling data’s story into five areas:
- Use a story structure: Creating a story structure in your data by using characters, setting up the challenge and what hurdles have to be overcome. What do you want your board to do with this as a result? “The more thoroughly you can explore your data, the more likely you’ll find the dramatic insights that make for a great story,” according to a whitepaper published by Tableau.
- Be authentic: It’s best when you can make a personal connection that taps into board member’s emotions. You can do this by using metaphors or an anecdote that helps to make the data more memorable. Use relatable examples such as sports or current events or a topic you know your board is most interested in outside of work. This will help them connect to your message faster and with that emotional hook. Couple that emotional hook with qualitative data. Selectively present your core facts and data to prove your point that you’ve set up using your metaphor or anecdote.
- Be visual: Use pictures, graphs and charts when possible. Make sure they’re readable on a presentation screen (i.e. don’t use 8 pt. font in an Excel spreadsheet). Also, don’t use distracting colors or patterns that take attention away from the data at hand. Use graphics to help strengthen your point. For example, if you’re talking about a competitor, an image of a predator or a threat may be more effective than a declining arrow on a table with disparate figures.
- Make it easy for your audience to follow: Being simple and direct is the best approach. By keeping your key issues to three or less, you can show how it relates your audience in a non-overwhelming way and you can get to the core matter faster. Your board will remember concise issues and you’re utilizing their time in a more respectful way that throwing your top 12 issues at them and expecting an immediate recall and action on each and every one.
- Invite and direct discussion: What does the board need from you the most? Highlight the most crucial facts that are threaded throughout your story such as the current state, rate of change, or a key number. Keep the conversation going with your board with a follow-up discussion after the initial meeting, write a blog post about it or post it in your company newsletter to keep it top of mind. “The payback that comes with a great story is that it gets people talking and sharing their points of view,” according to Tableau.
2. Compliance is like marketing
Think about it – you have to spread compliance across your organization. You’re pushing out the messages and trainings and processes to your employees to get them to do something and take action, especially in the event of reporting misconduct or disclosing conflicts. Marketing teams in every industry do the same thing – they are trying to push out a message to an audience to get them to do something (usually purchase a product). That message to buy that product has to resonate with different audience segments, and as such, marketing teams cater and craft their messages to audiences in different ways from language adjustments, cultural considerations, format differentiators and channel distribution strategies.
“Think of it this way,” said Quinlan. “McDonald’s has done a great job at marketing themselves as a fast food chain that when you are hungry, you think of them. Compliance can be thought of the same way if you market it well enough to your employees when they are in a situation such as at a dinner where a client is offering an expensive bottle of wine as a gift, they know to think of compliance and they then know to do the right thing.”
Compliance is the exact same – you have to craft your messages and communication and training to different employees who all receive and react to messages differently. You have to get them to take an action when the time is right and when compliance makes the most sense, such as when they are out to dinner with that client who offers them the expensive bottle of wine and they know because of your trainings and messages that they are not allowed to do so. You have to market to them so that when they are in certain situations like this they think of compliance at the right time and act in an ethical way.
3. Training: Know How to Talk the Talk
Compliance officers and their teams struggle with knowing what to say to employees in every kind of situation that can arise. But yet, knowing all of those situations is arguably impossible. The human element is a tricky aspect to fully predict. However, developing the skill to speak toward the issue with respect and without emotion is something that needs practice to hone and refine. Using a tactical approach by analyzing trends in cases will help you dive deep into patterns around topics.
You can then take those hot topics and compile use cases around each one. Set aside research time and role play different scenarios with your compliance cluster heads or use as training moments for your company. By doing this exercise, it will help craft this much-needed skill and determine a level-set relationship with your employees to come to you with a case. Additionally, it will help you determine the root analysis of a case by taking the conversation further and deeper by knowing how to talk the talk in varying scenarios while simultaneously growing employees trust in you and in compliance.
4. Bring focus to tone in the middle
PwC tells us that while many argue tone set by the top is the most powerful tool for reinforcing behaviors, those who set it from the middle and bottom is just as, if not more, important. “Tone can be a powerful force in preventing poor behavior,” the PwC states. When you have one bad apple in a decentralized team, one attendee shared, it’s hard to track that bad apple down quickly. The culture at the HQ office may be healthy and robust, but carrying that culture into each decentralized team is challenging. By ensuring the tone of the organization is consistent with your-mid managers as it is with the executive team and even your junior level employees, it limits the risk of having one or two bad apples from rotting away something that takes a long time to create like ethically-driven cultures. By having a consistent ethical tone throughout all teams, centralized and decentralized, you can more easily determine if the misconduct is a one-off incident or a deeper, systematic cultural problem. Check in more often with an offsite team, ask more questions and remind them to keep the communication open.
It’s surprising how many companies, no matter size or industry, still lack a dedicated compliance department or function.
Compliance still sits in legal or HR and is a person’s responsibility for only around 10 percent of their time. Those with dedicated teams have only have a handful (if that) of head count to get work done. But yet, regulatory frameworks are honing in and piling on more and more expectation from a compliance point of view. Training, for example, is often times split between or relied on help from HR or in-house attorneys – folks who aren’t necessarily trained to train compliance. There is a gap in communication between investigation and audit roles to the compliance teams. Some IA positions don’t know the correct person in their organization who is responsible for compliance to rely messages to.
Often times, those who find themselves in a compliance role by pure happenstance like an in-house attorney or GC simply don’t speak the same compliance language or communicate in the same way as many employees, which creates a perspective disparity. If you find yourself and your company in a similar position, consider ramping up project managers to deliver compliance messages and remove the “talking heads” who only go out in the field once a year. Project managers are often times received better by employees and are trained to manage situations that fit the expectations of different kind and types of people not to mention they likely have an existing relationship with the employee cluster they work with.
Our next Tech Talk is June 23 in Chicago. Register here!
How Better Reporting Changes the Game for Compliance
12 – 2 p.m.
Speaker: Patrick Quinlan, CEO, Convercent