How to Change Your Program for the Better!

The mouths of some of the people in the audience were agape. And who could blame them? The other panelists at my recent session in Amsterdam at the European Compliance and Ethics Institute were talking about incredible programs. One was based entirely around behavioral science, and another that basically ran itself with all the data whirling around. These programs are cutting edge – audacious even. And nearly everyone in the audience was thinking, “Wow, that’s all so awesome. It’s inspiring. And it would never, ever, ever fly at my organization. No way, no how.”

My job, both at this conference and at Spark Compliance, is to talk about the organizations I’ve seen pull off massive programmatic shifts. It can be done. There are different strategies to making it happen. Your best bet depends on the culture at the company, budget, and willingness to change.  

How to change your program for the better text over a dark blue background with a stick man choosing which of two paths to take.

Which Ride Do You Want to Be On?

Step one is to figure out how big a change you want to make at first. Strategy can make all the difference in this. Let’s say you want to move to an integrated, digitally-driven and AI-enhanced compliance program. Or, let’s say you want to change your whole program over to one utilizing behavioral economics. There are different ways to do this. You could go with a small, medium, or big bang approach.

Taking the Turtle Route

The first approach is to start really small. This is the sneaking-in-the-side-door approach. Nobody even sees that you’re there. For our digitally-driven program, that may simply mean approaching HR to find out where they keep all of their systems data relating to investigations or exit interviews and asking whether you can get a log-in to understand the reporting capabilities.

Or, for behavioral economics, perhaps you can write in your follow-up emails that 75% of employees completed their training on time, which utilizes social pressure to nudge employees to take their training sooner.

No one is likely to see these actions as sea changes. From there, you can keep taking more and more ground. You’re playing the long game here. Small changes compound, then over time, you’ve got a new experience.

A turtle swimming in the ocean

Rock the Boat (but not Too Much!)

The second approach is taking the middle ground. This isn’t the big bang. This approach is driven by a desire to move the boat in the right direction, as opposed to rocking it violently. There are a couple of approaches to this that I have seen be successful.


Try a Pilot

The first is to try a pilot. Start by defining your vision for change, then pare it down so it could work in a pilot format with a function, region, or business unit. People love the word “pilot.” It’s smaller than wholesale change. It’s non-committal. I mean, if it doesn’t work out, no harm, no foul right?

But a successful pilot creates proof of concept and lessons learned. It can create fans or even business-person testimonials. Now you’re getting ready for the big bang, but you’ve got data and proof. Good stuff.

One of our clients used this approach for a third-party due diligence program overhaul. They needed a simplified system that brought together all of the different third-party review activity. So they started in Indonesia. They knew they’d need a better screening and records management system, but they used the ones they had with a better workflow to get proof of concept, then were able to present the project to the senior leadership group with a case study and stories.


Ask Forgiveness, Not Permission

The second middle of the road approach is to ask forgiveness, not seek permission. If it goes right, people will be grateful for your clever initiatives. It can be a dangerous game, but some people win it this way.

In a recent ECEI, I presented on Sandvik’s compliance initiative, called Compliance House. Their CCO at the time had hired a developer to create APIs and configure Teams app functionality to create a by-location dashboard that fed into their risk assessment. It was genius. When asked about it, he said that he realized it would only take a few thousand dollars from his dedicated budget, so he did it without asking permission first.

Rather than sell it to top management, he created it then let them see his vision in real time.

Starting with the Big Bang

The last approach is certainly the most efficient, but also, for many, the most difficult to pull off. This is the big bang. This is where you tear up the current playbook and make wholesale changes. The shift may require a big change in technology spend, with adoption of more integrated cutting-edge systems, or it may require people to re-learn procedures relating to compliance. One way or another, this will be disruptive.

How do you ask for the Big Bang change? In my experience, the best way to do it is to start by describing, in vivid detail, the outcome. Start with the utopian world where data identifies risk before you’re even aware of it using AI solutions that are trolling reimbursement requests for unusual spending patterns or the names of government-related entities. Describe the magical world where training is truly bespoke to the company and role, so that it is more effective.

Magnifying class on top of printed data

Use the Numbers

Then pull out the numbers. For instance, if you want to invest in bespoke eLearning rather than the off-the-shelf version, show the outcome that aligns with the vision of the leadership, its priorities and solves a pain point.

We had one client that really wanted to overhaul their training program to make it bespoke and data analytics-driven. They needed new materials and a new delivery system. They had 10,000 employees and two hours of mandatory eLearning each year. Their employees’ hourly average wage is $50 per hour. OK – that’s $100 of time cost per year, per employee, or $1 million. We found that the bespoke courses cut out the fat of material not specific to their employees, so the time could be cut down to one-hour of laser-focused content. The investment in bespoke training saved the company $500,000.


Align with Their Priorities

Next align your priorities to those of the executives with the initiative. Do the executives want a less time consuming and less expensive way to deliver mandatory compliance training? Heck yes! You can promote the time and monetary savings and align to their interests.


Give it a Name

If you’re undertaking a huge transformation, give the project a name so it can be referred to easily in shorthand. It’s clunky to say, “our big project moving toward a data and analytics-driven compliance program utilizing AI.” Instead, call it, “Project Move” or “Project CT” for “Compliance Transformation.”

It Can Be Done

Change isn’t easy, but it can be done. Change can come in small, incremental ways. It can be introduced at a medium pace, or it can be done with a big bang. It doesn’t matter which tack you take, it matters that you start.

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Kristy Grant-Hart

Kristy Grant-Hart is the founder and CEO of Spark Compliance.
She's a renowned expert at transforming compliance departments into in-demand business assets.