Why Do Compliance Programs Fall Short of Expectations?

The Challenge

Organizations are making significant investments in their ethics and compliance programs. Risk assessments, policies, training, disclosures, whistleblower hotlines, third party due diligence, surveys, audits, and assessments. They all contribute to an effective program. Yet, in our day-to-day interactions with Chief Compliance Officers, we have identified a common reason why programs often fail to achieve their goals – the inability to put in place an effective process for managing continuous improvement.

A great example of this shortfall occurs with compliance audits and program assessments. Many companies go to great lengths to audit and assess their ethics and compliance programs. But when it comes time to implement and track completion of program improvements, many organizations lack the tools and processes to effectively follow through.  The challenge is not just large projects, but also following through on day-to-day activities such as mitigation of conflicts of interest and case management remedial measures.

Managing this important process often falls to the compliance team, who are being asked to do more with limited resources and increasingly distributed teams.  Considering the multitude of initiatives across the compliance program, tracking completion of these projects can be overwhelming.  So, how do effective compliance teams manage continuous improvement and ensure appropriate follow through?

The Solution

Managing Continuous Improvement and Follow Through

As we have worked with our customers, we have found that a consistent and automated approach to managing continuous improvement is a best practice.  Attempting to manage each project and task individually results in items falling through the cracks. It also results in a lack of good data on progress and completions. 

In order to address these challenges, we see compliance teams taking the following actions: 

  • Inventory and Track Centrally.  Maintain a complete inventory and track all projects and tasks centrally.  Depending on your internal management approach and organizational structure, you might have multiple parts of the organization managing projects but tracking them centrally is key.

  • Prioritize.  Continuously review projects and prioritize them to ensure resources are allocated to the greatest risks.  Recognize that without a centralized tracking process, it makes it nearly impossible to prioritize and allocate resources appropriately.

  • Assign Clear Ownership and Set Expectations.  Accountability is key to any successful project.  Ensure every project has clear deliverables, owners, deadlines and desired outcomes/KPIs.  What gets measured, gets done!

  • Communicate Consistently.  Create a consistent process that provides notifications and captures all communications. Ensure real-time updates are provided on an ongoing basis.

  • Report Regularly.  Report on progress, status, and results on a regular basis to ensure accountability and appropriate allocation of resources.

Digitization and The Role of Technology

Many organizations are already implementing these best practices but are still failing to follow through consistently.  That failure is primarily driven by a lack of an effective technology to support basic day-to-day compliance activities.  Programs have many solutions in place for specific compliance activities, like hotlines, learning management and third-party due diligence systems.  But they don’t have solutions to connect, prioritize and act on a daily basis across their program.  In fact, most programs today are still managed through disconnected systems, emails, and spreadsheets. 

These system limitations coupled with the significant number of activities being managed by the compliance team make it nearly impossible to stay on top of progress and respond to changing developments.  Without a system to manage all the above, it also makes it hard to monitor activity and communicate to leadership the value being delivered by the ethics and compliance program.

To effectively manage continuous improvement, you need technology that supports your program and your activities driving collaboration, accountability and transparency.  As you consider technology to support your program, best practice solutions are: 

  • Automated.  Programs can no longer afford to allow their core program tasks from identifying risks to managing projects and reporting to be handled manually.  Manual processes waste significant time and resources across the organization.  With today’s cloud-based technologies, managing your projects and tasks can be easily automated. Effective solutions allow compliance teams to clearly define and track deliverables, owners, deadlines and results; deliver real-time updates and reminders; provide a full audit trail and document attachments; and simplify reporting and data analytics.

  • Data-Driven. As the Department of Justice continually reminds us, good data is central to a successful program.  Any system must allow you to efficiently collect, structure and analyze data consistently.  This data will allow you to improve transparency and reporting driving better decisions faster. 

  • Connected.  Finally, these systems should be connected.  They don’t require that you replace all your systems to be on one platform. Rather connected solutions bring together the underlying systems and data that are generating the projects and tasks.  This approach will allow you to simplify program management while placing actions in context and tying them to your overall program and risks.

The Conclusion

The volume of activities and speed of change for ethics and compliance programs is accelerating.  As a result, the need to consistently follow through and drive continuous improvement is more critical than ever.  Implementing these best practices and technology changes will allow you to not only deliver, but also continuously improve.  They will also increase productivity, improve decision making and reduce risk.

If you face any of these challenges and are interested in learning more, please contact us at info@informed360.com.  

Action Plans

informed360’s Action Plans module allows you to track and manage your ethics and compliance projects and tasks all in one place.  You know who is doing what, when, where and how.  Communications are maintained in the system providing accountability and promoting collaboration.  With a complete audit trail and the ability to tie back to the underlying systems of record, you get a completely auditable and informed360˚ view of your actions and program.  Reporting and justifying resources have never been easier.  

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