This is the fourth in a series of five posts suggesting best practices for implementing corporate cultural change.  For an overview of all the tips on this subject, check out this preview post.  The first post in the series was about tone at the top and conduct to support it. The second post discussed the role of consistent, visible enforcement in promoting organizational justice and fairness.  Last week’s post focused on the importance of putting concrete, values-based policies in place.  Today’s post will be about implementing procedures that are consistent with those policies.  Next week, on March 27, the fifth and last post in the series will suggest how compliance professionals can foster a culture where employees are effectively engaged in awareness and communication to combat risks and support controls.

Last week’s post focused on the importance of creating and implementing policies that sufficiently and authentically support systemic responsibility for reform and intention for improvement.  Just as the appropriate tone and conduct must be observed from the highest levels of the organization in order to support enforcement efforts in the event of misconduct and abuse, corresponding policies must follow in order for the cultural norms to thrive.

For the standards set by the policies to succeed, organizations must put in place procedures that dictate practices which are consistent with and supportive of them.

Creating and implementing concrete, values-based policies is critically important for organizations to demonstrate operational commitment to improvement.  In order to take material advantage of momentum for reform in the examples set at the top in both attitude and behavior, as well as to nurture the culture of compliance created to support organizational justice and fairness, the policies in place must formalize this all.

Corporate compliance professionals should seek to create and communicate procedures that include the following traits in order to support a culture of compliance and enable progress, encourage organizational integrity and moral engagement, and protecting the vulnerable while punishing and preventing wrongdoing.

In order to accomplish this lofty goal, keep in mind “The 5 C’s” of procedures to implement for corporate cultural change:

• Credible – Any procedure intended to prevent abuse, punish wrongdoing, and protect individuals must be believable.  Individuals asked to follow procedures must find them credible and believe that if faithfully executed, the risks and dangers they are intended to prevent or mitigate will be successfully addressed.  Regular review and the opportunity for ad-hoc adjustments, and transparency about the frequency and seriousness with which both of these tasks can be undertaken, will promote the believability and reliability of procedures.
• Concise – It’s imperative that procedures are understandable by all.  They should not be so academic or theoretical that individuals using them struggle to know what they require and direct.  Concise procedures are practical ones.
• Convenient – Convenience has two aspects with procedures: first, the ease of physical delivery and retrieval, and second, the quality of actual user experience.  Don’t put the procedures deep in the labyrinth of an intranet site or high on a shelf in a binder no one will ever open, and be sensitive to employees who may work remotely or with alternative accommodations.  Taking care of people who may not see e-mails or receive announcements at head office also allows compliance officers to “put a face to the name” and get some important personal contact with these individuals so that they know who to contact with questions and may feel more comfortable doing so.  The procedures also cannot be so burdensome in their steps or include so much complicated background information that they can’t be followed by the average reasonable employee.
• Considerate of the audience – Further to concise, clear language in, and practical delivery of, the procedures, organizations should consider the audience fully in all stages of procedure provision.  The procedures should never be written and provided just to tick a box.  It’s so important to keep in mind that these are not just regulatory compliance obligations or requirements on a spreadsheet that must be completed.  Procedures must be used and relied upon by individuals.  Those audience members are the most important stakeholders and participants in the procedures, and drafting and implementing the procedures must be done so with great intention toward being considerate of them as the top priority.
• Constructive – In reliance of the foregoing posts, and above all other considerations, the efficacy of procedures is imperative to make them useful.  Therefore the procedures must be constructive and aimed toward encouraging and enabling the real processes and interactions that are necessary for reform.  The desired result is a positive, fair corporate culture where people can speak up and speak out as well as work together toward creating an organization which reflects their own values.

Check back next week, Monday March 26, for the final post in this series of five, which will suggest best practices for going beyond training, in order to create convincing and compelling employee education campaigns and communications.