We continue our series of thoughts on compliance fundamentals with a piece on the importance of building a culture in which people feel comfortable asking questions and speaking up.
Once employees are conversant with the organization’s conduct expectations as a result of the training and communications program, it is time to focus on culture or the environment in which those standards operate. Importantly, the organisational culture or environment must allow employees to feel safe raising concerns about potential violations of the company's Code of Conduct, policies and procedures, individual misconduct, or simply asking questions in case of doubt or uncertainty. Acknowledge that speaking up takes a lot of courage and create trusted mechanisms to guarantee that any concerns will be treated with strict confidentiality and the utmost respect for the people involved. Organizations may choose or be required by law to put in place anonymous channels for complaint handling.
Complaints must be thoroughly investigated following principles of respect, fairness, and objectivity. This requires an open and transparent investigation process so that employees know in advance how the reports are handled and what an investigation looks like. Effective investigations must be timely conducted by qualified personnel to ensure impartiality and due process and, most importantly, guarantee no retaliation. Tracking the results of investigations helps the company measure the effectiveness of the process and analyze potential trends or red flags that can be factored into the risk assessment for continuous improvement of the organization's culture.
This is a challenging step and one which requires sensitivity, good judgment and encouragement. Nevertheless, smart organizations stay focused and stay the course to ensure that they create and maintain a positive speaking up culture in which employees can ask compliance questions and get answers.
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