Medieval witch doctors believed that viruses were caused by foreigners. All you had to do was build a wall or a moat to keep the foreigners out and no illness would befall your village. Modern medical science has evolved beyond that simple prescription. One of the things modern medicine has brought us is the honest communications about how to stop, slow and best avoid communicable diseases. In the face of a federal government which wants to build a wall or moat to stop coronavirus, American businesses have taken the lead to protect employees, to the extent possible, during the coronavirus pandemic. And of course, there is more honest communications.
It looks like travel will now be shut down, at least through the end of April, if not longer for most US companies. This travel ban may well also include a ban on face-to-face gatherings of one or more persons. Of course that will impact corporate compliance functions. However, if planes, trains and automobiles are not available to you to communicate about your compliance program or educate with in-person training, what can you do? Obviously e-learning and other similar strategies are available to you. Why not use the opportunity to take things a step further and try some new compliance communication and learning strategies?
What about an internal corporate podcast series around compliance? Sound far-fetched? As a strategy for this point in time, it could well work for you in way that old techniques do not. Think about telling the story of your compliance efforts through a podcast series. First, it can be incredibly cost-effective for any Chief Compliance Officer (CCO) to tell their company’s story of compliance. Further, it involves no travel as all the episodes can be recorded remotely. There are a variety of communication tools which allow you to communicate and record the audio, GoTo Meeting, Skype and Zoom are but a few. You do not even need to be in front of a computer, as you can phone in to each of these, literally from across the globe.
Once again, although multiple persons might be involved in the actual recording, there would be no face-to-face contact. This means that the second of the most recent corporate pronouncements would also be satisfied. Equally important, all of this means you would have no additional hardware or software costs to record.
Finally, think about the possibilities of topics. You could have a training series which looks at specific compliance issues: third-parties, gifts, travel, entertainment, charitable donations or any of the myriad topics which not only compliance practitioners face but also employees who are on the front lines of operationalizing compliance. You can have micro-podcasts of up to 60 seconds on one topic as a compliance reminder. Listening to one compliance topic for up to 60 seconds will not induce compliance fatigue but it can be incredibly useful to not only strengthen your overall compliance regime but, under Hallmark VI of the Ten Hallmarks of an Effective Compliance Program, work to demonstrate robustness and effectiveness.
But why not take it further and develop a podcast series around a compliance topic. You could look at a specific Foreign Corrupt Practices Act (FCPA) enforcement action. You could take a deep dive into one of the mega-cases, Airbus, Ericsson, Petrobras or a similar matter. Conversely, you could take a more confined and defined Securities and Exchange Commission (SEC) enforcement action, which has only one or two key compliance concepts to tell a more focused story.
You could make it specific to your company. Why not tell the story of a successful compliance event. Consider a large contract your company has recently bid on and won. Why not tell that story through the sales cycle from the compliance perspective. It could be such straight-forward steps as (1) customer ID and initial contact; (2) steps in response to RFQ; (3) RFQ win and contract negotiation and (4) contract execution. You could talk about all of these steps from the compliance perspective. It would not only educate your workforce on compliance but demonstrate how compliance facilitates business operations. In other words, it would act as a marketing tool for your corporate compliance function.
You could utilize your internal social media to publicize each of these podcasts. Your marketing team can create some uber-cool graphics to go out when each podcast premiers. You can then follow up during the week between podcast episode issuances with additional cover art or graphics to drive more traffic. You can add features which allow you to see who has clicked through to the listen to the podcast so you have an audit trail if a regulator ever comes knocking.
The beauty of all of these approaches are, as with almost all things in compliance, you are only limited by your imagination.
Business is not going stop because of coronavirus. The bad guys who engage in bribery and corruption are not going to stop either. As a compliance professional, you may be working from home but that is not going to stop the need to be ever vigilant and continue to communicate and train. So why not try something new and different. You might well find that your employees not only appreciate your efforts but respond more than positively as well.
Finally, if you need any help to flesh out any of this give me a ping.
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