Talk is Cheap — Unless You Back It Up

Move beyond the basics and bring meaningful data to the table, regulators say

This is part 1 of a 3-part series, dubbed Talk is Cheap. 


Balance the input data and the output will be a commensurately compliant company

Regulators, specifically in the US, have shouted from their bullhorns that training program rates and confirmation/completion stats are no longer are going to satisfy them. The urge behind companies to use meaningful data is pungent.

Not only will the appropriate C&E metrics help determine if your program is effective, but they can make the case of asking for more resources to fund the compliance and ethics office a successful one.

HOLD UP: Before you read any further, grab a copy of the latest resource from the Resource Center, a short e-book entitled, The Data Age. This series goes deeper into topics discussed there.

“From climate change and political issues all the way to compliance and ethics, these issues are all brought to our attention with supporting data,” says Donald Farmer, principal at Seattle-based TreeHive Strategy. “Without that supporting data, we begin to lose trust in the validity of a claim.”

Essentially, when you present something, you need to be able to back it up with supporting data and then show the analytics for your next steps on how you will solve the problems at hand.

Many compliance metrics track activity rather than impact, thereby demonstrating that compliance may be busy but not necessarily effective, pWc says.

Take into account the following when pulling data from around your organization. These elements are what the Foreign Corrupt Practices Act (FCPA) considers meaningful data:

Meaningful data in the eyes of the Department of Justice includes, but is not limited to:

  • Number of transactions or deals that were stopped, modified or more closely examined as a result of compliance concerns – how many payment transactions were most closely examined? How many new business deals were nixed because they exemplified a potential bribe?
  • Look at the number of requests for compliance and ethics resources that have been denied.
  • How many third parties were suspected, terminated or audited for compliance issues?
  • The number of third parties or acquisition targets re-evaluated under the acquirer’s standards/policies.
  • How many audits were conducted on acquired business units?

SO WHAT…Why is it so great that you can tie analytics to compliance? What is the business benefit of it?

Not only is pulling the right kind of insights and data points so very important to see the health of your program, but you have more actionable data to drive (and sustain) business performance.

Important to know: there is a distinct difference between “reporting” and “analytics.”

Reporting is looking at the past, analytics is then using the information to look into the future. Think: proactive versus reactive.

Ok, let’s not get ahead of ourselves. We are not advocating for everyone to just turn their back on gut feeling, intuition and that small thing called human behavior. What we are advocating for is for these anecdotes and other intangible elements to be backed up with some heavy-weight champions from the data arena. They’re the best pair a professional in any field can depend on.