How to  Spring Clean Your Compliance Program

My favorite place to be is in my backyard, with the sun shining on me, in my oversized comfy chair watching the birds or reading a magazine. During the winter months, the sun becomes scarce. I try to scratch out some time on the weekends, but it’s often too chilly, even in my home near Los Angeles, to really enjoy the warmth.

Ah, but now the sun is shining into the evening.

Daylight savings time has come, the birds that wintered away are now returning, and my bougainvillea, which I’ve named “Mae,” is once again covered in bright fuchsia flowers.

And all that means it’s time for a spring clean.

The Origins of Spring Cleaning


Sources differ on the origins of spring cleaning. There are rituals and celebrations during the spring months in Judeo-Christian, Buddhist, and Persian traditions, as well as Yogic practices.

Everywhere in the Northern hemisphere, as the sun returns, windows re-open to let in the light and the breeze, and people clean up their homes from months of dark and dust. Spring cleaning is the process of washing away the old and brightening that which remains.

Spring Cleaning Your Program


There’s often a flurry of activity closing out the previous year, followed by the frantic planning and goal-setting of January. Everything is moving so fast that we don’t even see the dirt anymore – and we just get used to it.

Spring is an opportunity to clean up your compliance program to see it in the bright light of day. It’s easy to get into a rut. By asking yourself these four questions, you can make your program sparkle the way it should.   

1. If I could start over, what would I do differently?


Pretend you’re beginning again, but with the knowledge you have now. What would you do differently to structure your program for success?

Would you entirely revamp your risk assessment process?  Would you re-brand your whistle-blower hotline to make it more accessible?  Would you implement short-burst training intended specifically to address adult learning? (You can learn about adult learning theory here.) 

By mentally giving yourself an entirely clean slate, you’ll see where the program can most benefit from change. 

2. What good idea have I not yet initiated?


Did you go to a conference last year and hear a great idea that you just haven’t implemented yet? 

Have you read or pulled out an article in this magazine that you’ve intended to use, but haven’t? 

Did you hear from a friend about a terrific structure for a compliance and ethics ambassador program, but haven’t found the time to create one yourself? 

Take out those ideas you’ve been meaning to use.  Write down at least three, then choose one and commit to employing it. Make a timeline for it and choose your milestones. 

Before you know it, your program will improve.

3. What complaints do I get most often?


There’s a famous phrase in entrepreneurship: complaints are opportunities. The theory is that when people complain, entrepreneurs can rush in with a solution to the problem that people will buy.

What complaints do you get about your program? People are more likely to buy – that is, buy into – your program if you resolve their complaints.

Do people complain about the cumbersome third-party due diligence process?  Do they say the policies are unreadable?  Or that policies are hard to find on the intranet?  Think about the complaints that you get most often, then choose one to tackle head-on.

For instance, if people complain about training, think about how you can make it better. Try out new vendor options so you can see what’s out there, even if you’ve still got a current contract. Think about creating your own using online video systems. Use to create more compelling slides or to create infographics to disseminate as job aids that double as training tools. You could also gamify training using Compliance Competitor, the innovation-award-winning business simulation game perfect for training higher-risk teams.

If you can’t think of a complaint, seek feedback from employees.  Once they trust that you really want to know, you’ll find out what they really think, and can then address it.

4. What would I do if money were no object?


If you had an unlimited budget for your program, what would you do? 

Would you invest in world-class, bespoke micro-learning training?

Would you hire an improv team to work with your salespeople at their annual meeting to teach them how to respond to high-pressure ethical situations? 

Would you hire a graphic artist to re-brand your Code of Conduct and program’s marketing materials?  Your answer to this question can help you to identify the areas of your program that need the most time and attention. 

Think creatively about how you can bring in some elements of your great ideas now with the budget you have.

Call your e-learning vendor and offer to be the pilot for a new micro-learning option. 

Seek out the local drama club to see if they can help you develop some fun theatrical exercises that you could use with the sales team. 

Ask the intern in the marketing department if they can help with graphic design. 

Sweeping away the old and bringing in the light is a fantastic metaphor for cleaning out what’s old and stale in your program. By considering these questions, you’ll brighten up your program and make it better at the same time.  

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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.