Stop Cramming and Start Measuring Your Compliance Program’s Effectiveness
A generic, check-the-boxes approach to workforce compliance is like cramming for a test: it doesn’t actually lead to long-term learning and change. Remember cramming for tests? The all-nighters, the bleary eyes, the delirium, the unholy amounts of liquid caffeine? It’s an experience that’s hard to forget.
But while the memory of cramming sticks, the actual information we were desperately shoving into our brains back then is another story. The problem with learning something just to prove you’ve learned it is that as soon as the test is over, all those dates, facts, names, and formulas disappear like so much tepid coffee down the drain.
Workforce compliance isn’t all that different. At least that’s the assertion in an in-depth and thought-provoking article entitled “Why Compliance Programs Fail—and How to Fix Them,” which recently ran in the Harvard Business Review. Over the course of nine pages, Hui Chen and Eugene Soltes—a former compliance expert with the US Department of Justice, and a Harvard business professor, respectively—make the case against compliance and ethics programs that exist merely so organizations can point to them and say, “See? We invested in compliance.”
A generic, check-the-boxes compliance approach, Chen and Soltes argue, consistently backfires or falls short. They write (emphasis added):
“Some companies may be willing to invest significant time and resources in compliance and ethics programs because they see them as critical to the organization’s long-term success. But we’re pragmatists. We understand that with all the other competing demands on a firm’s limited resources, the ever-present regulatory and liability concerns often become the rationale driving compliance efforts. Yet this focus on the regulatory aspect is exactly why it’s critical to get serious about measuring outcomes. As compliance programs continue to be more closely scrutinized, those that cannot show meaningful results will fail to meet the stronger regulatory standards being applied today. To put it more bluntly, if the best that can be said for, say, an anti-corruption training course is that employees finish it, prosecutors, courts, and regulators are not going to give a company credit for having an effective program.”
In other words, you can’t just create a policy, train employees on it, have them sign off, and expect compliance to improve. In today’s regulatory climate, organizations face greater pressure than ever before to demonstrate that their employees are actually learning, retaining, and applying policies.
That may sound like a rationalization for spending even greater resources on compliance but, in fact, the opposite is true. As the authors point out, organizations that throw money at the problem rarely see results. Chen and Soltes write that what organizations need is not more compliance, but smarter compliance:
“Many executives are rightly frustrated about paying immense and growing compliance costs without seeing clear benefits. And yet they continue to invest—not because they think it’s necessarily productive but because they fear exposing their organizations to greater liability should they fail to spend enough. Employees, too, often resent compliance programs, seeing them as a series of box-checking routines and mindless training exercises. In our view, all this expense and frustration is tragic—and avoidable.
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The answer, we believe, lies in better measurement. At its core, the idea is as simple as it is crucial: Firms cannot design effective compliance programs without effective measurement tools. For many firms, appropriate measurement can spur the creation of leaner and ultimately more-effective compliance programs. Put simply, better compliance measurement leads to better compliance management.”
Click here to read “Why Compliance Programs Fail—and How to Fix Them” in the Harvard Business Review.
At Compli, this simple truth is one of the guiding principles behind our workforce compliance automation software. Our platform gives managers the tools to measure and report on compliance initiatives with up-to-the-minute detail—not only because it’s what regulators require, but because it’s the one way to truly ensure compliance. If your organization can’t learn, it can’t improve—and unlike the way things were in the cramming days, there’s no passing or graduating from compliance. It’s on ongoing responsibility, so choose a platform smart enough to help you meet that responsibility with minimal hassle and long-term cost.
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