Maintaining a Culture of Compliance
I get this question often: “How do I get a ‘culture of compliance’ to embed in my company?” The culture of compliance is established and maintained by senior management through consistently voicing the tenets and support of the culture of compliance, and then demonstrated by their behaviors and enforcement within the program. Easier said than done. Firms with an effective culture of compliance have senior leaders that talk-the-talk and then walk-the-walk, where they continually remind the organization of its values and principles, and then lead with the poise and posture that reflects those values and principles (tone at the top). They cascade this through the organization by demanding the same from lower management, including the messaging and modeling (the mood in the middle). In fact, lower management is formerly evaluated on each individual’s ability to uphold and embed the culture of compliance. To complement this layering of messaging and modeling, senior leaders are also openly supportive of the compliance leaders, often providing “a seat at the table,” and eliminating the common behavior that marginalizes compliance and treats the discipline as non-additive. The compliance team creates the internal messaging and training that is distributed in conjunction with management (a unified front to create a buzz at the bottom) and acts in a service capacity to the organization as the steward and coach for maintaining the culture of compliance. Then there is the messy work of monitoring and enforcing to maintain the culture of compliance. The critical piece here is for the unified picture of compliance and senior management to be prominent and true, where the organization does not view compliance as “cops” or “auditors” but rather the eyes and ears of management AND each other, in order to maintain the asset everyone has a vested interest in: the organization itself. When these components are moving in a similar direction, the culture of compliance blooms and can integrate throughout an organization. It might seem a little amorphous in the “team spirit” tone. The truth is that the culture of compliance in an organization is often the barometer for the organization’s health and can forecast the future trajectory of an organization.