As I write this blog post I am watching the crew working on the road in front of my office. It has been a long 5 months, yes COVID has impacted us, but we have also been unable to get into our office parking lot due to a complete reconstruction of First Street where our office sits. The same patch of dirt in front of my office has been dug up and compacted no less than 15 times by 10 different contractors over the course of the project. The first question that comes to mind is “What a waste, why don’t they just do everything they need to do all at once and save all that digging and compacting?” The answer is, things have to be done in the proper sequence. Doing work out of sequence results in damage to the new structures being placed underground and a project that does not work the way it is supposed to work once it is completed.
I can’t help but think about how this same principle applies when building a compliance program. Without proper sequencing in the development process, the compliance program will not function properly or be as effective at detecting and deterring bad activity. It is so important to begin the process of building, or evaluating, a compliance program with creating a solid Code of Conduct that sets forth the core principles on which the organization operates; the key pillars for the organization that won’t be compromised. Once the Code of Conduct has been developed, policies and procedures that support the Code are developed to establish the systems and expectations for how the business of the organization will be carried out. Next comes training staff and stakeholders on the Code of Conduct and supporting policies so everyone in the organization is fully aware of the ethical standards adopted by the organization and the expectation that each employee adhere to those standards.
Once staff and stakeholders have been trained a program of auditing and monitoring is put in place to simply make sure the systems (policies and procedures) are working the way they are supposed to work and generating the desired outcome which is ethical behavior. Training establishes the expectations and a progressive discipline program reinforces the organization’s commitment to the compliance program. When discipline is administered in response to a violation of the compliance program staff understand compliance is more than just a binder that sits on the shelf.
Lastly, responding to any violation of the compliance program by revising the process that allowed the violation shows the organization’s on-going commitment to doing the right thing.
Taking any of these elements of a compliance program out of sequence increases the probability the program won’t be as effective in achieving the desired result, an organization where employees do the right thing, the right way, at the right time. The road construction in front of my office is nearing the end and soon we will have a brand new road, drive and parking lot that will serve us well for many years to come all because the project was completed in the proper sequence.