We kicked off the 2016 Compliance Tech Talk series with a bang, thanks to all the compliance professionals who attended last weeks’ roundtable lunch in Seattle! The room was packed, the conversations were buzzing and compliance professionals were able to share ideas, ask questions and problem solve.
Setting the Stage
Before we get into all the details of what we learned from the event, let’s take a few minutes to discuss our audience and topic.
16 Companies were represented, including:
- Colliers International Property Consultants, Inc.
- Computer Sciences Corporation
- Expeditors International
- Holland America Group
- Lynden Incorporated
- Microsoft Corporation
- Moss Adams LLP
- Saltchuk Resources
- Sutherland Global Services, Inc.
- Weyerhaeuser Company
Out of all the companies who were represented, we had various titles, including:
- Chief Compliance Officers
- Compliance Managers
- General Counsel
- Director of Legal
- Chief Risk Officer
- And more…
With a myriad of differing responsibilities and industries at the event, it allows different perspectives on the distinctive topics we covered – which we love! It is always great to hear what a CCO is responsible for at one organization and how those same responsibilities might fall under the Director of Legal at the other. Being a young role and profession, it seems like no matter the title compliance professionals are wearing many hats to effectively manage their compliance program.
We focused the conversation around one of the biggest challenges compliance professionals face: mining data and how to steer away from simple metric reporting to analytics to help better align compliance with business operations.
Other topics we discussed included how to:
- Implement sophisticated reporting and analytics for better business alignment,
- Increase the relevance of compliance metrics and reports, and
- Quantify and measure the compliance program’s impact.
Key Takeaways & Insights
Since there were so many great examples that were shared here is the cliff notes version.
Trend #1: Data, data and more data!
A question that gripped the audience quickly was:
How do you bring disparate data sets together to identify correlations to start understanding why things are happening, not just what is happening?
Thank you very much for providing a forum for excellent thought-sharing. It was well done, valuable and enjoyable.
Heads nodded, pencils were moving and everyone looked around the room hoping there was an easy solution. Since reporting to the Board has shifted in recent years from simple metrics (hotline numbers, training courses completed, etc.) to predictive analytics, many attendees were interested in how other professionals are conquering this major challenge.
One attendee shared great tips of how he has been able to build out a compliance program in the last three years. He shared that by pulling data together from different parts of his company, he is beginning to have that dynamic conversation with the Board on where outliers start and why this is happening. It was very exciting to hear all the areas he is pulling data from to get a truly full picture of his program as he looks at his compliance data. He mentioned that he mines his data to add richness to his Board conversation from HR, direct entry forms, disclosures, benchmarking reports and others. The only challenge he mentioned around this approach is that it is manual and time-consuming when you have to export so many different sets of data to Excel and sort, create pivot tables and more to get a holistic understanding.
To gather insights from data faster, many compliance professionals are re-evaluating the technology they use. Having all this information in one place paints a clearer picture and helps teams really dig into issues- and enables those levels of reporting — leading to more sophisticated data-driven decisions. Every number has a story, and it’s the compliance professional’s job to help tell it well.
Patrick Quinlan, our fearless CEO, shared an example of how current Convercent customer was able to track and report on the behaviors, organizational influences and environmental factors that drive misconduct. These data points provide more color to that full picture. While many attendees shared they would love to implement this approach, they lack access to crucial data points. Yes, they have access to their basic compliance programs like hotline statistics, survey results, training reports, etc, but they are limited to certain areas to mine the aforementioned data and make those correlations. Do you also struggle in this area? Here are the 4-Haves for Program Reporting.
Trend #2: Do you leverage a disclosure tool to collect more data?
Since many attendees were wanting more data and were eager to hear how other companies were getting doing this, Patrick brought up disclosures. Why not connect your disclosure tool with case management, policy and training history to allow you to continue to drill down on information to really understand the motivation behind employee behavior and noncompliance. Not only does this help them focus their efforts where they’re actually needed, but provide them correlations and guidance on what to focus on instead of blindly creating more policies and procedures.
A few examples that were shared varied by process and who was involved:
- Survey to the entire company
- Email to only senior level executives
- Software provider with a disclosure tool
- Included disclosure questions inside their code of conduct
Many compliance offers are now involved in setting company strategy and COI tracking, which could be a huge game changer for many organizations. Compliance professionals can shift from looking at the past but look forward in a predictive way to prevent incidents from happening. Predictive analytics is where the industry is headed, and you as a compliance professional, need to be prepared.
From COI, Patrick curiously asked about Gifts, Travel and Entertainment. There shouldn’t be any if’s, and’s or but’s, BUT it does happen. We had one attendee share that they track GT&E and the importance around this when it comes to inbound disclosures for merchants.
It’s easy for you as a compliance professional to know about your gift and entertainment policies, but it’s impossible for you to police everyone else’s offsite actions. If an employee is careless about the policy and accepts an out-of-limit dinner or gift, what do you do? Most at the event agreed with a culture of reiteration and retraining, especially, before an employee heads to that conference or client meeting. A way to avoid a G&E issue is to get ahead of it with a friendly reminder of your organization’s policies.
Trend #3: The Importance of Compliance Culture
Relationships matter. The better they are across the organization; the more information you will be able to mine. For example, some attendees had great relationships with their HR department so it allowed them to easily meet with them and leverage their HR data to add more richness to the overall compliance data.
One great example that compliance departments are doing to help increase transparency across the company and set the standard of how important compliance is, the company shares real stories about compliance both good and bad by generalizing information give employees first-hand knowledge what is happening throughout their organization when it comes to compliance.
Lastly, tone from the top is also important. An attendee gave a great example. They once had culture issues and are now seeing a positive difference with new leadership. We all know the familiar saying well that it “starts at the top”, but what about starting the tone in the middle? Reach out to your directors and middle managers to help set the tone and push it up if you feel the top isn’t very ethical or lack an understanding of compliance in general. Sometimes it takes a bit of managing up to perk the ears and spark action from the powers that be.
We are hitting the road next month to Washington DC and Atlanta!