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[author: Cherelle Johannes]
We were delighted to interview Kevin Parley, Fellow of the International Compliance Association (ICA) and Deputy Chair of the Data Protection Forum, for his insights and observations of whistleblowing roles in UK organisations. Kevin has worked in financial services, retail banking and insurance for over 20 years, bringing his knowledge and understanding of ideas that these sectors and others can implement to this article. This is part two of two. You can find part one here.
Please note that Kevin’s views and opinions discussed in this interview are his own and are not representative of the views of the Data Protection Forum or the ICA.
How can companies ensure that employees who are not directly involved with ethics and compliance are aware of their responsibilities in carrying them out?
If we focus on frontline employees, managers who can initially handle whistleblowing issues (concerns raised by their staff) on a daily basis will rely on a credible whistleblowing policy and ethics (ESG) policy. Effective functions carrying these responsibilities are led by the Ethics Officer, the Whistleblowing Champion and the Whistleblowing Officer, who must also play their parts.
If you don’t have reliable training for these policies it is immediately doomed to failure. If the organization cannot maintain a speak-up culture, and if communication audit trails are not present among your frontline staff, the achievement of these important goals will also fail; They should live and breathe throughout the organization.
Second, if we are talking about a large organization, you may have an ethics officer completely separate from your whistleblowing champion, officer, and potentially your compliance officer. So, in that case, how do you juggle frontline staff between multiple roles communicating different aspects of a shared program?
These roles should link to each other and send consistent messages to frontline staff. If conflicting messages are communicated to you, then frontline staff will not be invested. Sometimes this is easier said than done and this will only happen with the active cooperation of key stakeholders.
How might these roles differ, and how can you effectively align them when they may be involved in different functions in the business?
A compliance officer ensures that the company complies with legal and regulatory obligations. However, compliance involves a certain level of practicality about what can realistically be achieved to the best of the organization’s abilities with minimal impact on profitability or the ability of employees to perform their roles.
On the other hand, the ethics officer works in a way that requires him to think in a more abstract sense of broader, non-regulatory ethical questions. These two roles will not say the same things because they are different roles with different objectives. However, if they say the opposite Things, then, put the organization and its staff in a challenging situation. Both roles must work well together, align through regular meetings and ensure they consistently send messages to frontline employees to invest in process and culture around risk, compliance and ethics.
The role of leadership in alignment
Overall, investment in these objectives comes from the top. Your leadership team – including your CEO, whistleblowing champion and ethics officer – should use language on a day-to-day basis that reinforces the importance of achieving those objectives and communicates in a way that front-line staff recognize and understand. doing. Senior management must be willing to transparently have difficult conversations and set an example for frontline staff that it is okay to speak openly about ‘concerns’, or the program’s objectives will not be successful. Imagine senior management to middle management using ethical language in the day-to-day delivery of products and services, in how they talk to and about their customers—that’s the ideal path to a successful ethics and compliance program.
It does not mean using complicated language. These themes and expectations should be accessible to all staff using everyday language and easily understood concepts. And ultimately, common sense should take care of itself. If your staff feel uncomfortable about a particular concern and feel like something isn’t right, they should feel like they can talk or ask about it, even if they’re not sure it’s a reportable issue. Is or not. .
What methods would you suggest for organizations to promote compliance among their workers?
Large-scale town halls are a valuable means of promoting a specific business objective. This should be designed as a special event that staff are encouraged to attend, with senior management and leadership teams also present.
This should last a couple of hours – lunch would be ideal – and could take place in a designated conference room or a nearby hotel. Staff love these events because they are also networking opportunities, and those who are too busy or unable to show up in person can catch up virtually at other times, as the event must be recorded.
Another suggestion, in my experience, is to make sure your intranet is regularly used to promote specific compliance and ethical goals. Having these messages available and accessible in a front-page intranet format, which staff will see every time they log on, ensures visibility of goals and achievements in delivery across the business.
Is there anything else organizations and role holders in whistleblowing, risk and compliance can do to strengthen the suitability of a good risk and compliance program?
In fact, the crucial thing is to ensure continuous and in-depth communication from senior management to their staff. There is no point in doing set training once a year that is then put on the shelf until next time. It should be regularly reinforced by management that if any member of staff raises a concern, it will be taken seriously – and they will not be negatively labeled or discriminated against. Instead, it should be shown that the person raising the concern is a valued member of staff who has helped to avert real risks in the organization.
One of the most valuable steps an organization can take in this sense is for senior leadership to bring transparency to the benefits brought about by those raising concerns. Regardless of the type of concern, you want staff to be in a position where they feel safe enough to tell you about potential business risks.
Cases of people speaking up should be celebrated. For example, ‘This helped us avoid a stock market crash for shares in our business’ or ‘This report helped us avoid being subject to regulatory enforcement action’ or ‘We did the right thing as a result of concerns by our customers. is brought up’.
This type of messaging needs to come from senior management as a powerful reinforcing signal of a real organizational hero driving positive change.
These examples of positive action are significant for more junior staff as they will instill confidence that they will not be ostracized, labeled or stunted in their career progression if they raise concerns. Building trust means that all staff – including your junior staff members who might otherwise be too concerned to speak up – will use the organisation’s legitimate whistleblowing channels to raise concerns. They are better off going to the regulator or the press to air their concerns publicly. Without trust in business processes and integrity within frontline staff, internal reporting will never happen.
All of the above suggestions speak to driving the culture within the organization by re-enforcing the importance of achieving key compliance and ethical goals, so as to achieve board-level goals and maintain the long-term viability of the organization. confirm it.
Kevin Parle Deputy Chair, Data Protection Forum and Fellow of the ICA
DP-Forum welcomes new members to its ranks. If you are interested in finding out more, please visit www.dpforum.org.uk.
View the original article in Risk and Compliance Matters
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