A Compliance Experiment in GIFs

Any compliance professional worth his or her salt knows that clever communication about ethics and compliance policies is crucial to winning over employees’ enthusiasm. So when a compliance officer (who shall remain anonymous) shared with me a prototype “anti-bribery compliance through GIFs” — well, that was too good not to publish. 

Therefore we humbly submit this vignette of corporate misconduct, told with GIFs and text. Is it funny? Does it accurately reflect the eye-rolling exasperations of corporate life? Does it hold your attention and impart the important compliance lessons by the end? Read on, and let us know!

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It all started with a sales exec in the EMEA division who needed to go the extra mile to close a sale to the Ministry of Taxation.



The managers on the sales desk back at corporate headquarters were sympathetic, but appreciated the delicate situation here.



The sales desk approved “discounts” to be offered to the Ministry, which of course were instead used to fund bribes to the foreign government officials. The EMEA sales team was supposed to keep quiet, but someone is always bound to spill the beans by accident.


Before long, someone back at headquarters decided this was wrong and should be reported to the compliance hotline.



You can imagine how that went over, once people realized they might get in trouble for violating the anti-bribery policy. Some made outright threats to the whistleblower.



Others communicated their displeasure with subtle innuendos and by excluding the whistleblower from typical workplace socialization.


The whistleblower, however, held true to their principles even in the face of adversity.


An investigation ensued.



The FBI and the Justice Department started digging into the allegations. The company realized it would need to settle the case.



First came a $40 million monetary penalty the company had to pay.


That meant lots of open positions going unfilled and lots of budgets frozen. 


The company also imposed a suite of more restrictive policies to clean up the corrupt corporate culture.


Now the compliance team plays a more direct role in approving sales to overseas customers.


Those folks in the EMEA division and on the sales desk who approved this scheme in the first place?



Eventually new managers embraced the company’s higher ethical standards and a culture of compliance. 



That whistleblower? They endured some tough times, but two years later won a $6 million award for speaking up.


The rest of us were left to pick up the pieces. So the moral of our story is:

  • Our company doesn’t pay bribes to win business. 
  • When you do offer bribes, you put the whole company at risk and people suffer.
  • When you see coworkers violating company policy, call the compliance hotline. 
  • Don’t retaliate against people calling out misconduct. 
  • Do the right thing from the start, and over the long run we’ll all have a better experience at work.

Thank you.

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OK, I’m back. The above is one compliance officer’s attempt to make anti-bribery training a bit more entertaining, engaging, and effective. It certainly beats lots of the written policies I’ve seen. (Although several years ago I recorded a podcast interview with Mary Shirley at Fresenius Medical Care, who had held a contest for employees to translate compliance policies using only emojis.) 

What do you think of the GIFs approach? Drop me a line at [email protected] and let us know!

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