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Steps To Building a Strong Ethics and Compliance Program

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Steps To Building a Strong Ethics and Compliance Program

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One of the biggest hurdles when it comes to improving ethical programs involves getting employees to comprehend what’s expected and what you should expect. If you look over the typical Code of Business improve ethics programs (or any other name you choose to use) there will be sections on “complying with all laws applicable” or something similar. This is an extremely high bar to set for the majority of us. We’re not trained legally and aren’t competent to make judgments about compliance solutions with the law (found in certain ethics programs) that cover

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Ethics Insight: Benefits of Ethics and Compliance Risk Management

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Ethics Insight: Benefits of Ethics and Compliance Risk Management

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Corporate Compliance is all about knowing what exactly makes your business successful in the current days. Not only that, but it also involves other aspects that help to make it even better in the future times.

So, this is regarded as an important element of the growth plan. If you are also seeking to grow your business, then all that you need is to opt for the M&A advisory services.

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How To Develop An M&A Strategy That Helps In The Growth Of Your Business? -

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M&A strategy is all about knowing what exactly makes your business successful in the current days. Not only that, but it also involves other aspects that help to make it even better in the future times. So, this is regarded as an important element of the growth plan.

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What is the Relationship Between Ethics and Risk Management?

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What is the Relationship Between Ethics and Risk Management?

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Is it helpful if I tell you, “Pack a bag for a trip”? Possibly not, at least without some context. For this post, the luggage’s content is the ethics; the destination represents risk.

All those pleasant words organizations say about their values, mission and purpose are a statement of intent. Many such terms link to ethics – integrity, transparency, honesty, value, accountability, fairness, teamwork, inclusion, and trust. You get the picture.

Bridging the gap between what you pack and where you’re headed is ethics and compliance risk management.

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Is it helpful if I tell you, "Pack a bag for a trip"? Possibly not, at least without some context. For this post, the luggage's content is the ethics; the destination represents risk.

All those pleasant words organisations say about their values, mission and purpose are a statement of intent. Many such terms link to ethics - integrity, transparency, honesty, value, accountability, fairness, teamwork, inclusion, and trust. You get the picture.

Bridging the gap between what you pack and where you're headed is ethics and compliance risk management.

Lost in translation

Grand words without intentional direction never travel well. Corporate values have become synonymous with performative fluff for a disengaged workforce and sceptical consumer and stakeholder community. If you think that's a bleak assessment, run a search for employee engagement data; at best, only half of us want to go to work.

Yet, we are communal animals (for the most part), and the ethical words are ones most of us would proudly wear as a badge of identity. Why do we, therefore, not engage with these corporate values? Because organisations send employees into ski resorts in sandals. The grumpy and demoralised workforce meets customers who can see and feel the disconnect.

Can't we just prepare a bit better?

Pack your bags; we're off
Back to my unhelpful order earlier, where you might ask questions including:

1. Where are we going?

2. What will we be doing?

3. When are we going and for how long?

4. Who are we going with?

5. How will we get there?

That's ethics and compliance risk management. Where you operate, what you do, how long you've been doing it, who you work with, and how you do it (routes to market, value chain, etc.) all have a significant bearing on your risk profile. Let's demonstrate with a couple of examples.

The transparent and honest casino

If you suspend any moral, religious, or other objections to casinos, they exist for a purpose. They might claim their mission is to give people escape and a good time, but is it? Using the checklist above:

1. Where do casinos operate? Places with favourable regulations, low taxes ideally, and near populations who like to gamble.

2. What do they do? They take more of your money than you will ever win by ensuring the odds are always in their favour.

3. When/how long? As long as possible, using tricks like windowless rooms so we can't tell the time of day, free drinks (to keep us there and impair judgment), and occasionally distracting entertainment.

4. Who do casinos partner with? Junkets, organised criminals, exploited local communities, touts, entertainers (see the point above), corrupt politicians; not all, but enough for that list not to be libellous.

5. How do they do it? By playing to some of our baser instincts and ensuring the house always wins.

So when a casino picks its values, mission and purpose, might transparency and honesty merit mention. Nah, I didn't think so. Maybe words like adventure, risk, excitement, and fun might pass the test? Being honest about the clothing required for a trip is ethics and compliance risk management.

Imagine a social media platform that shows you a blend of things you like and those which enrage you to keep you scrolling, clicking, tapping, guffawing and gnawing. I know, it's so hard to do.

Do you think that the ethical code on the corporate homepage includes some of the words I listed above? Do you believe them? I used "integrity, transparency, honesty, value, accountability, fairness, teamwork, inclusion, trust." Which of those words might fit? Teamwork, maybe, inclusion, perhaps (assuming a wide caucus of people are allowed to voice their views). What else?

You didn't pick accountability, transparency, fairness, or trust, right? Is this tech company accountable in the current regulatory environment? Do they treat competitors and uses of their platform fairly? Are their algorithms and reasons for promoting or demoting content transparent? Do you trust them and the feed they show you?

My point is not to slam social media companies - they provide many conveniences, connections and opportunities - it's that not all ethical buzzwords fit all organisations. As Denzel Washington's character in The Equaliser - a man very comfortable with a unique brand of ethics - says, "You gotta be who you are in this world, no matter what."

Ethics and compliance risk management

You cannot have an ethical framework that isn't aligned with your risk appetite, tolerance, and profile. To move ethics from flimflam and bullshit bingo to something more substantive and representative of an organisation's realities, we must first answer the who, what, where, how, and when questions. Only then can we pack our luggage such that employees who join us on this journey are prepared and aligned with the reality they will face. Consumers can then make informed decisions.

I disagree if you think that a whiff of honesty would spell doom for many companies. We all make Faustian bargains - the low-cost airline that treats people like livestock or the high-end fashion brand that burn stocks of dead cow wallets and purses at the end of each season.

If you're still not convinced, have you ever found yourself favouring a jerk over someone a bit slippery and untrustworthy? I am picking the more polarising examples in the interests of word count and expediency, but the point is simple. There's room for values, mission, and purpose that match risk realities without anyone falling off their seat in astonished shock. This practical approach is ethics and compliance risk management, so pack your bags!

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The Ultimate Guide to Effective Compliance Risk Management

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Is it helpful if I tell you, "Pack a bag for a trip"? Possibly not, at least without some context. For this post, the luggage's content is the ethics; the destination represents risk. All those pleasant words organisations say about their values, mission and purpose are a statement of intent.

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The Importance of Compliance Risk Assessments

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The Importance of Compliance Risk Assessments

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Let’s start with what’s not a corporate compliance risk assessment – reviewing internal controls. At best, that is benchmarking or an audit of sorts. These reviews have their place, but they’re a health check to my mind. We need a lifestyle analysis for a more rounded risk assessment – a proper corporate compliance risk assessment.

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Let's start with what's not a corporate compliance risk assessment - reviewing internal controls. At best, that is benchmarking or an audit of sorts. These reviews have their place, but they're a health check to my mind. We need a lifestyle analysis for a more rounded risk assessment - a proper corporate compliance risk assessment.

External factors

We can't estimate risk without understanding the organisation's external lifestyle. A five-person technology start-up developing NFTs in a coworking space in Hong Kong faces almost none of the same risks as a sizable Honduran aquaculture business supplying some of the United States' biggest restaurant chains.
The first step in a practical corporate compliance risk assessment is to map the basics:

1. What you do.

2. Where you do it.

3. With whom you work.

4. How you work (model and markets).

If you're struggling to conceptualise these ideas, we have developed a straightforward (and high-level) external risk assessment tool here, which you can complete for free. You can gather this information using a blend of surveys, workshops, and interviews, usually quite quickly. The trick is to avoid asking complex questions or using risk jargon. For example, avoid asking people to estimate likelihood using words like "possible, sometimes, probable, etc.". If you're inviting many people (via a survey), it's often easier to ask us to estimate in percentage terms. When we pick numbers or values as a group, we tend to be accurate at the median point.

For workshops, I like tools including Mentimeter to allow anonymous (and therefore more honest) answers to simple questions. If we're trying to assess integrity risks - including corruption, fraud, and conflicts of interest - I might ask:

Who poses the biggest corruption risk? Allow the respondents to pick multiple options from your usual stakeholders (clients, central government (licenses & permits), local government, subcontractors, suppliers, etc.).

How likely are the following risks? Then list options on a slider (0% to 100%), including requests for bribes from officials and paying officials extra to do their jobs properly.

Whatever tools or tactics, the goal is simple: reduce complexity, provide anonymity, and gather as many relevant opinions as possible. Technological tools coupled with targeted follow-up interviews seem to be the most effective methodology. Once you have this picture of the external lifestyle of your organisation, it's a lot easier to develop an internal corporate compliance risk assessment right-sized to the pressures you will realistically face.

If you need more detailed guidance or advice on gathering this information within your organisation, let us know.

Physical health

With a fuller picture of the lifestyle factors, we can move on to analysing the internal controls - also known as benchmarking. Our goal is to focus on those areas of most relevance. One of the problems with many so-called risk assessments is treating all controls as equal. Imagine you are planning to build a house. We need to know about our environment to choose the right location, materials, security systems, and features. Is the area fire or flood-prone, who lives nearby, what are the crime statistics, will we be connected to the grid, etc.

In the corporate compliance risk assessment context, we might focus less on payments to intermediaries if the organisation sells online, direct to end-users. Or we might need to assess if training is remote-enabled and accessible without a company email if our business involves flexible or contract labour (like in retail). We shrink the scope of the analysis to those controls and systems relevant to our risk profile.

When it comes to asking questions, keep it simple. Again, I like to use sliders, as there's something more intuitive and spontaneous about them. For example, suppose I'm trying to assess integrity risks, including fraud, corruption, and conflicts of interest. In that case, I might ask, "Are the following drivers of risk? To what extent?" I'd use a slider with disagree and agree at either end, and questions might include:

Pressure to hit targets

Lack of understanding of compliance

Lack of systems & processes

Lack of leadership support

Lack of compliance resources

Actions of others (partners, suppliers, clients)

Local and customer culture

It's always helpful to focus on what causes internal risk - the behavioural analysis - rather than review controls in isolation. Going back to the building a home analogy - if our schematics and planning are flawless, but the construction crew are hopeless, the overall security of our new home will be compromised. Once the property is built, the most outstanding security systems in the world won't save us if our kids keep leaving windows open, we don't back up the CCTV feed, or we leave the alarm off. The internal risk analysis must focus on both the hardware and software.

If you're stuck for inspiration, we have a compliance maturity scorecard assessment to get you started.

Mental wellbeing

Analysing our risk software (human behaviours) is a natural segue to the final stage of our health and wellbeing review. An organisation's mental health might be better described as its integrity or ethical culture. We don't blurt out, "Are you depressed, anxious, etc." to understand mental health. We usually ask questions designed to understand the underlying mental state and follow up with targeted questions.

It's the same in an organisational setting. We have an assessment of your integrity culture here to get you started. What we want to understand is the well-being within the organisation across four domains:

Accountability - how do leaders and managers behave? We also need to know how accountable they are.

Knowledge - do people have the right resources and support to identify (potential) issues and respond appropriately?

Trust - how do you assure people that you will listen and protect them when they speak up? We also need to understand if people can say, "I don't know, understand, agree", or "I made a mistake."

Accessibility - do people have access to timely support and help to address ethical challenges?

A 360 health check

Bringing together the external lifestyle factors, the health of internal controls, and the organisational mental well-being affords us a 360 perspective - a proper corporate compliance risk assessment. With some creativity, a sprinkling of technology, and most importantly, good questions, we can get this comprehensive lifestyle analysis affordably and quickly.

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How to Conduct a Compliance Risk Assessment? | Club Oxigeno

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Let's start with what's not a corporate compliance risk assessment - reviewing internal controls. At best, that is benchmarking or an audit of sorts. These reviews have their place, but they're a health check to my mind. We need a lifestyle analysis for a more rounded risk assessment - a proper corporate compliance risk assessment.

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3 Tips On How To Implement A Strong Ethics Program

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3 Tips On How To Implement A Strong Ethics Program

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Many times, the resources available are limited and budgets are tight. You are, in this case, being asked to improve the Strong ethics program! I’m using plural since most in-house teams adjust their programs according to the needs of different audiences, regions and stakeholder groups.

What can we do to help make this easier? It all depends obviously on how you manage your risk and where, when, and who you work with, but let’s focus on the how to improve ethics programs: prevent and detect, then respond and explore the hacks that we can come up with.

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Regulatory compliance solutions in Singapore | Ethics Insight

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Regulatory compliance solutions in Singapore | Ethics Insight

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Ethics Insight’s approach to ethics and compliance risk assessment is 360°. We start by considering the context; what you do, where you do it, how, and with whom. Compliance Solutions early work was in anti-bribery and corruption risk assessment, where it’s essential to understand the demand-side of risk and the impact of refusing unethical demands. We take these lessons into all our external assessments, helping you identify issues many don’t uncover.