Communicating the importance of ethics and compliance to a diverse workforce is a critical part of a corporate compliance officer’s job. Alas, it’s also a challenging (and sometimes thankless) part of the job, too. So today we’re going to hear from one compliance professional about how she brought the message of compliance to her company’s workforce of 110,000 across the globe.
I caught up with Mary Shirley, senior director of ethics and compliance for Fresenius Medical Care North America. Fresenius works in kidney care, running thousands of dialysis clinics in more than 120 countries. Shirley is in charge of ethics and compliance training, and she recently held a “compliance week” — five days of games, gifts, and gimmicks to help employees understand what the compliance department does and why they should consider compliance allies rather than buzzkills.
What exactly did Shirley do? You can hear the details in our full podcast conversation (15 minutes) at the top of this post. Meanwhile, here are a few points that stood out in my mind.
Balance the Goofy With the Practical
No compliance extravaganza would be complete without goofy games and activities. Fresenius held scavenger hunts, a compliance-themed Jeopardy show, and even “compliance campfires” where Shirley and her colleagues hosted meet-and-greets in the conference room. (“Come see us for s’more information!”)
That said, Shirley is the first to admit that the compliance function doesn’t bring in revenue for the organization. So while it may be tempting to splurge on fun times, the point isn’t simply to show everyone else how cool the compliance personnel are. “It’s important for us to show the value add for the initiatives we do,” she said.
Shirley also stressed the importance of thinking about the remote parts of the enterprise. Larger offices always have a critical mass of employees, including compliance officers on site, so planning activities for them is easy. Yet Fresenius, for example, also runs clinics in rural areas without any compliance officers nearby. Those folks need love too, so consider how to involve them via social media efforts where they post their participation for others to see.
And, the compliance campfire events. Were actual campfires lit in the conference room? Because that would be way cool.
“America is a litigious society,” Shirley admits. “We used cardboard cutouts and projectors onto a screen.”
Outreach Now Saves You Time Later
Why bother with compliance outreach events at all? Because one good extravaganza can introduce the compliance function to a wide range of employees — and introduce the function in ways that stick, rather than through waves of email messages that often don’t.
Shirley said her foremost goal was simply to establish rapport, so employees know that compliance isn’t the enemy. After all, she added, many employees might not naturally encounter the compliance function until they are on the receiving end of an audit or investigation. “That’s not the most positive light.”
If your compliance extravaganza can inform employees about the protocols of how to report an allegation or collect documentation, great. The paramount objective, however, is simply to build familiarity and trust. Do that, and they’ll follow your lead through all the protocols and details later once a specific situation arises. That’s victory.
Think About Feedback
Yes, a compliance festival should include questionnaires or surveys to solicit feedback from employees. That’s a given.
Shirley, however, stresses the importance of unsolicited feedback. It’s a valuable point; unsolicited feedback is more genuine, and therefore more useful. “The unsolicited feedback is the real gauge as to how well you’re doing,” she says.
So devise at least a few ways to let employees submit that unsolicited feedback. For example, at Fresenius’ compliance campfires, Shirley’s team had a flip-chart where employees could offer one-word responses to “What word do you associate with compliance?” — and someone wrote down “No.”
“That’s actually a good thing,” Shirley said, because it told her that at least some parts of the organization still viewed compliance as a drag. “We still know where to target our communication and dialogue.”
If your company does something interesting for compliance communication — or if you have an activity even more hokey than “Come see us for s’more information!” — drop me a line at email@example.com.