The Importance Of Corporate Value Statements To Compliance Programs


valuesI always comment that we live in a world of ADHD – no one really focuses on anything these days.  Instead, they pick and chose from the stream of sensory bombardment delivered electronically to everyone through the Internet.

We all love Twitter for that reason, but have you ever noticed how many people rely on Twitter as their primary source of news?  It is a sad commentary when everyone starts communicating in less than 140 characters.

Chief Compliance Officers face a daunting task in competing for the attention of managers and employees.  With all the pressure on managers and employees to perform, CCOs know they face some serious obstacles.

In this era of electronic overload, it is no accident that many companies are adopting brief value statements to complement their ethics and compliance program.   A statement of value principles – a brief statement including a headline of three to five words to describe the company’s ethical principles – is becoming more common among larger, multinational companies.

A value statement provides an important communications tool for a company’s commitment to ethics and compliance.  It is a way for a company to brand its to brand its compliance program and give important guidance to managers and employees.  It also facilitates senior manager communications as a way to advance a tone-at-the-top.

Cynical readers may scoff at such a program as “dumbing down” compliance, but I think they miss the point.  A brand for ethics and compliance can be an important communications tool.  It should not be the sole focus of a communications strategy but it certainly can be used as one of several communications tools.

There is a danger that the statement of value principles centered on three to five single words (e.g. Integrity, Commitment) can dominate a communications strategy.  On the other hand, it is a quick and easy device for focusing attention on ethics and compliance, and bringing more awareness to managers and employees.values2

The CEO and senior managers must be strong advocates of the value statement, and use it to guide their specific messages.  The value statement has to become associated with current management.

Also, the CCO has to integrate the value principles into the ethics and compliance program.  Training sessions, surveys, compliance messages, all need to reinforce the values and demonstrate how the values are reflected in the compliance program.

Most companies are up to the challenge of coordinating the values statement and the ethics and compliance program.  It is a very effective strategy for advancing a commitment to compliance.

Companies which face significant remedial tasks in the wake of a government enforcement action would be well advised to include a values statement as part of a new approach to ethics and compliance.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Michael Volkov, The Volkov Law Group | Attorney Advertising

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