
Standards for waivers of conflicts of interest
While some organizations bar conflicts of interest in all cases, many opt for allowing COIs to exist where appropriate. But how should appropriate be defined for these purposes?
by Joe Murphy
You do the compliance training in your company. There is a ton of advice out there on how to train, and you use the best ideas you can find. But one common element of training is that, as soon as the training is done, people move on to other things. The lessons and impact of the training begin to fade. So what can you do to boost the impact and longevity?
Adam Balfour previously wrote an interesting piece for SCCE called “Does Your Organization Pursue a Culture of Compliance and Ethics Through Annual Performance Goals?” In his article he offers very useful ideas on performance goals for managers related to compliance.
So here is an additional goal that ties into the training. Evaluate managers on what they do to extend the message and impact of the compliance training. For example, a few weeks after the antitrust training, the sales manager could have a staff meeting where she asks her people “what do you remember from that antitrust training we had? What in your sales visits reminded you of those important messages?” In other words, the managers’ jobs include extending the training. This becomes part of their performance evaluations.
This ties in with a very important management point. While a company’s “tone” might start at the top, to the typical employee the most important person in management is the immediate boss. I may not even be able to name my company’s CEO, and I have no idea who is on the board, but I sure know my boss and what she considers important. If the boss is telling the team that the compliance training really matters, and actually brings it up a few weeks after the training, that is likely to be very memorable.
While some organizations bar conflicts of interest in all cases, many opt for allowing COIs to exist where appropriate. But how should appropriate be defined for these purposes?
Attending SCCE conferences is always a source of insights and new information. In these conferences I have seen quite a bit of focus on data analytics, and deservedly so.
The first time I saw Kristy Grant-Hart she put on a show about magic compliance dust and then brought the audience to reality by breaking the news that there is
In our years of assessing compliance and ethics (C&E) programs, my partner Jeff Kaplan and I have pinpointed several key attributes that we consider essential to an effective program, including