Tuesday, July 30, 2013

BUILDING EFFECTIVE COMPLIANCE PROGRAMS: It Takes a Village

“No member of a crew is praised for the rugged individuality of his rowing” ~Ralph Waldo Emerson

“If everyone is moving forward together, then success takes care of itself” ~Henry Ford


I had recently been contacted by an individual who had been tapped by her organization to launch a corporate compliance program. My colleague approached me with that perennial question, “How did you build your program?...” I paused to consider my response.

Despite the mythology to which some may wish to subscribe, individuals don’t design, build or improve corporate compliance programs alone. While certainly individuals contribute significant leadership, ideas, and work product to a successful compliance program, it is truly the efforts of interconnected contributors that weaves the fabric of the program.

From scoping and documenting the program charter through defining and populating a comprehensive compliance risk universe, it takes a village of invested professionals to build the program. Since a compliance program likely encompasses several lines of business and diverse operating functions spread across multiple locations, personal interaction with a variety of leaders and staff is necessary to identify, quantify, and rank risks across an organization. I don’t know about you, but I certainly have experiential limitations regarding various functions outside my areas of expertise. Without those subject matter experts, my program would be neither comprehensive nor effective.

Thus, while it would have been terribly tempting to my ego to lead my fellow professional colorfully through an anecdotal reprisal of my rugged journey to locate the holy grail of corporate compliance on a lonely mountaintop, my better angels prevailed. “Katherine, I’d be pleased to share with you how we built our program, and the lessons we’ve learned…” And with that discussion, another member was added to the compliance program “village.”

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