André Tourinho (andre.tourinho@oas.com) is a Governance, Risks and Compliance Officer at OAS in São Paulo, Brazil.
Compliance issues are very often a part of corporate discussions. Decision-making executives are worried about financial, operational, and management issues as much as about compliance duties of the corporation. Regardless of the size of the corporation, compliance topics are inserted in regular corporate obligations.
With that in mind, how can a compliance professional transmit the compliance culture within an organization? Is there a rule of thumb on compliance communications?
A compliance professional has to bear in mind that each organization requires a different approach in view of its particularities, original concepts, employees, business, market, and so on. There is no specific rule of thumb to communicate compliance matters, but there are a few tips that proved to be helpful in spreading an ethical culture.
What to do first?
First and foremost, assess who is going to receive the communication materials. Irrespective of the theme or message, it is important to consider the most appropriate way to communicate so that the public can better absorb what is intended. For instance, if you are dealing with employees with a low level of education, an email with extensive reading is not the way. You should consider using other materials, such as videos, animations, playful banners or posters, and short theatrical plays to captivate the attention of such employees.
On the other hand, if you are dealing with C-level executives who are already trained and/or qualified to deal with compliance issues, the communication has to be direct and succinct. The communication should be more comprehensive if the goal is to educate executives. It is important to highlight that a compliance communication cannot be used as the only source of education. Compliance education should be broader and consider external assistance, if necessary.
It is also essential to understand the employees’ perspective of their daily activities in order to insert a compliance obligation in their job. A surprising number of employees have no notion that they are doing something inappropriate. Compliance departments have a relevant duty not only to spread an ethical culture, but also to explain the limits employees are subject to. For example, it is not recommended to accept an offer of a complimentary meal from a service provider during a fee quotation of its services.
