Compliance Champions?
Yes , please – but what’s best?
Part II
When Spark Compliance is doing a compliance program review and an organization doesn’t have a Compliance Champions program, guess what becomes a key recommendation? That’s right – starting a Compliance Champions program. Why? Well, a Champions program has many benefits, chief among them:
Expanded reach for the Compliance Department
Greater visibility for compliance-related policies, procedures, training, and communications
More hands to make tasks easier
Better intelligence from the ground
An expanded number of people who are trusted to take reports of potential misconduct and answer questions about policies or rules
There is no one way to run a Compliance Champions program. Rather, there are considerations and choices to be made to have the most successful program possible.
This is the second of two blog posts detailing the considerations in creating or refreshing a Compliance Champions program. The first post can be found HERE. That post discusses options in choosing participants, incentivizing people to take the role, and tasks that can be assigned to Champions.
Important Questions
Once you’ve finished determining how Champions are selected, incentivized, and what tasks they will take on, the next questions relate to rolling out or refreshing the program successfully.
How do you kick off the program?
If you haven’t yet kicked off your program (or it needs a restart), having a great opening event can build enthusiasm quickly. A half-day or all-day meeting can make a great opening. There are many ways to have a great event. Some ideas include:
Bring in outside counsel to talk about scandals or war stories that relate to compliance meltdowns
Hold a skills-building workshop (investigations, public presentation, writing)
Bring in a branding expert to help people create their personal brands
Train on laws affecting the company in an entertaining, story-based way
Use the Compliance Competitor business simulation game with the teams
Hold a raffle for prizes
Perform a brainstorming session about interesting ways to communicate policies, procedures, and the Code
Bring in senior leaders to talk to the group and tell them how important they are
Hold a getting to know you networking session with all of the Compliance Champions to build cohesion and a stronger network in the company
Give an award celebrating someone who has been very strong in compliance or ethical behavior at the company
Take the afternoon off to a fun location for team building (g., rounds of mini-golf, an amusement park
Attend a local sporting even
Attend a performance/musical/play/comedy event
How do you keep people involved?
Once you’ve kicked off the Champions program, you don’t want it to die from lack of momentum. The best Champions programs have a solid structure and a consistent cadence of meetings and events.
As business travel returns, an annual in-person meeting is an ideal way to keep people involved. Quarterly virtual or in-person meetings can be a highly successful way of keeping people engaged. Keep the ideas listed above in mind, but also consider:
Updating the Champions on new laws or policies that will affect the company or their unit
Sharing investigations data/stories as much as possible
Highlighting one individual each meeting – sharing facts about the person’s life and interests
Continuing skill building
Further exposure to senior leaders
Having an annual award for one or more of the Champions
Going to a nice dinner
Having a company-sponsored happy hour at the end of the event
Having a sharing session where Champions discuss their:
- Concerns
- Areas of confusion
- Best practices
- Wins
Keep a consistent cadence of meetings so everyone knows what to expect (and look forward to!).
Is the role on top of the day job?
Some companies include the Compliance Champion role as a formal part of the employees’ job responsibilities. This is ideal, as it recognizes that the Champion role takes time away from the employees’ day job.
Unfortunately, in many companies, the Champion’s role is not considered part of the day job. If this is the case, it is important for members of the Compliance department to explain to the managers of the Champions that their involvement is valuable, important, and requires appreciation and flexibility to help them to complete their tasks.
Do you set formal goals and performance reviews?
An important question to answer is whether or not the role of Compliance Champion comes with its own set of formal goals, and if it is part of the employee’s performance review.
This may be easier said than done, as these types of goals will typically need to be signed off on by both the Champion’s manager and the HR department.
Formal goals can help create realizable expectations and give an incentive for the Compliance Champion to be engaged. It is beneficial to create specific annual goals for the Compliance Champions so they prioritize the work they need to do to assist the program and they are held accountable for doing what needs to be done. Formalized goals and performance reviews also give credibility to the importance of the program from an organizational standpoint.
If you can get these elements in place, you should.
How often are they changed out?
Another decision that needs to be made is how often the Compliance Champions are changed out. Typical choices include:
A specific cadence (g., every two, three, or five years)
Only when there is a new unit/function/region opened
When someone quits/retires/otherwise leaves
When the Champion themselves determines that their tenure has been long enough and chooses to leave
There are benefits and detriments to each of these.
For instance, having a specific cadence allows people to enjoy the benefits of being a Champion without feeling burdened by the commitment long-term. A specific cadence also allows more people to have the experience of being a Champion than would otherwise if the role is only replaced when someone leaves the company.
On the other hand, once a Champion is trained, they become a strong asset. People within the Champion’s region/business unit may get to know them and associate them with the role, which strengthens the likelihood that those employees would be comfortable reporting potential misconduct or asking for advice on ethical challenges.
Training takes time, and once a Champion is trained, they become a stronger asset to the Champions program and may be able to guide or mentor new Champions.
If people need to be “voluntold” (volunteered, but only under duress from the boss) to join the Champions program, it may be better or easier to leave Champions in place for as long as possible. If this is the case, try to make the program more enticing using the incentives described in the previous blog post so that people are keen to join.
Best Practices
No matter how you set up your program, some best practices remain the same. For instance, no matter how your program is structured, you should have a charter or foundational document defining:
The structure of the program
The leadership of the program
How the program is managed
How people are selected for the program
The major job duties and tasks of the Champions
How often (at minimum) the group meets
You should also clearly enumerate the tasks and expectations of the Champions both when they are chosen and throughout their time in the program.
Champions can be just that – champions of the program and ambassadors for the compliance department. Having a successful program isn’t hard, but it does take a lot of thought and planning.
P.s.: We at Spark Compliance have created an awesome downloadable checklist of considerations for creating or refreshing a great Compliance Champions Program. See it HERE.
