Ambassadors networks are worth it!

by Joe Murphy, CCEP

The 2024 SCCE Compliance and Ethics Institute was well worth the time spent participating.  One of the sessions I attended was on ambassadors networks, or what Matt Silverman describes in his book The Champions Network: A Blueprint to Expand Your Influence and Spread Big Ideas in Any Organization,  as “champions networks.”  This is one of the best ways to ensure that your compliance program has a reach throughout the company.

The session was an excellent example of our profession’s generosity in sharing ideas and examples. The presenter, Maryse Tremblay, shared the lessons learned from her experience, plus elicited valuable insights from the audience.

This is one area where the government agencies offering advice and suggestions about compliance programs seem to fall short.  It may not be accurate to say that compliance ambassadors are an absolutely necessary element in compliance programs, but there should be no question that they can play a highly valuable role.

Compliance champions in the HR department. Immediately before attending this session I had had the opportunity to propose this approach during an excellent presentation by representatives of the Canadian Competition Bureau.  Canadian competition law has been changed to add prohibitions on wage-fixing and no-poach agreements.  Under Canadian law (and similarly under US antitrust law) these are now treated the same as price fixing and other forms of collusion.  Yet HR folks may not have received or really processed this message. In that session I recommended that companies have compliance champions in their HR departments.  This would then provide a practical vehicle for getting this important message out and reminding people from time to time about its importance.  So I was primed for this next session.

Lack of support by business unit managers.  One of the interesting questions discussed is how to handle the business unit manager who does not support or assist the unit’s compliance champion.  On this one I suggested an answer that touches on another key compliance element:  using the evaluation and incentive system.  People complain that they don’t know how to use assessments or other incentives related to compliance.  But every manager, including heads of business units, should be assessed on their support of the compliance program.  This point would be entirely logical to apply here. The business unit or department head would be assessed on her support of the compliance program.  If the manager showed no support for the compliance ambassador that would show up in the manager’s assessment, and then in her pay and potential for promotion.  This is how companies communicate important messages.  It belongs in this context as well.  Companies use incentives when they want something done, and that point could easily apply here, to help make the ambassadors program successful.

Ambassadors are not just a tool for huge companies. The speaker also made an important point about where this approach can work.  In a previous article I had noted that the Health and Human Services OIG had issued a compliance program guidance where they only talked about ambassadors in the context of large companies, but this is not really the case.  Certainly a micro company with only 5 employees in a storefront does not need compliance ambassadors.  But whenever people are in separate locations/separate functions, there is value in this concept.

Part time or full time?  In the presentation it was noted that being a champion is typically only a part-time function of just a few hours a month.  However, where there are large sub-units, such as in substantial business units the person may need to be at a higher level and working on this mission full time.  Thus, for example, if there is a 3000-employee subsidiary responsible for conducting business in India, it might well make sense to have someone full time designated as the compliance officer for that unit.  But in general the guidance about part-time ambassadors spread throughout a business makes great sense.

A trusted local colleague. Another valuable role for the ambassador is to be a local, trusted colleague whom people in that area may talk with about concerns or questions they may have.  Yes, they may know there is a HQ compliance officer, general counsel, etc.  But human nature being what it is, people may be much more willing to talk with someone closer to them.  In the speaker’s example, they made sure that employees in each business unit knew exactly where the compliance ambassador was physically located, as well as providing the usual contact information.

An opening to a possible new career. The ambassador option can also serve as an introduction to a possible new career for some.  It can be an easy doorway to the broader field of compliance and ethics.  It may also give the local ambassador visibility among the company’s senior people who might otherwise have never even see this individual. This can be a tool in recruiting talented employees to serve as ambassadors.

Start wisely and slowly. The speaker also advised to start slowly, to learn the ins and outs first.  She reminded the audience that establishing a network like this will mean more work for the compliance officer, because the ambassadors will be seeking advice and assistance, especially in the beginning.  But even an experienced ambassador will want to communicate with headquarters when they have a new idea or have identified a new risk area.

Branding. To increase the visibility and impact of the ambassadors the speaker recommends developing a strong brand for this part of the compliance program.  This approach increases the likelihood that employees will take advantage of this local resource.  It can also increase the appeal of the role, which helps when trying to recruit new ambassadors.

Recruiting. There was a highly informative discussion about how to recruit new ambassadors.  The speaker did not think it a good idea to use senior managers, HR or others already in control environments. She would also not accept those put forth by local senior management, so the ambassador understood they owed allegiance in this area to the compliance team. In contrast to the speaker’s experience, however, others might find value in having the local management more invested in the selection process.   One audience member whose senior manager had scoffed at the idea that anyone would accept being an ambassador was amazed when 400 people applied for this type of position. So it might be the case that intervention by local management to obtain candidates might not be necessary.

Maintaining the ambassadors program. Of course, initial success in getting the program off the ground does not guarantee continued vitality.  It is important to take steps to nurture the program and to keep the ambassadors engaged.  One step is to have quarterly calls with the ambassadors.  These could include having senior managers joining the calls to note appreciation of the work the ambassadors are doing.

Another remarkable example of drawing the group together is to have an international, in person conference giving the ambassadors the perk of having an international trip.  In the speaker’s case the company agreed to cover expenses for the ambassadors to travel to a conference in foreign locations.  Such gatherings can provide training and also an important opportunity for networking. I personally worked with a client who did this very successfully and saw great value in this approach.  Another option discussed would be to have an ambassadors’ day, and to provide all the ambassadors with distinctive jackets which would demonstrate their favored status.

A suggestion for training the ambassadors.  A key element for a successful program is training.  The ambassadors should understand the risks the business faces and they should learn about the field of compliance and ethics. Based on my own experience, I would also suggest providing training on skills that were not only helpful for compliance ambassadors, but would also include life skills.  Two I would definitely include are public speaking, and active listening.  This would help make the ambassadors more effective in their compliance functions, but also empower them for success in other aspects of their careers.

If you do compliance work at a company where you to not see your entire workforce each time you have lunch, then a compliance ambassadors program is an option you should consider.