CCO Insight: Ethics and The Culture of Compliance

What are Chief Compliance Officers (CCOs) doing to create an ethical and compliant culture?  We have been asking CCOs to share their perspectives on the role of Compliance in facilitating an effective ethics-focused culture. Ideas discussed and related actions to take included:

Implementing effective Speak Up programs that aim at building internal trust through:

• Organizational justice (e.g., following up with employees on resulting and actions taken regarding their raised concerns)
• Creating forums that resonate geographically (e.g., Compliance Week, local ethics and compliance liaisons)
• Utilizing social platforms and enhanced Ethics messaging to engage with employees (e.g., use of QR codes, visuals, and screen lock pop-up messaging)

Measuring ethics and accountability through metrics and data analytics including:

• Company metrics, trend analysis and comparisons to peers
• Reporting team culture perceptions based on compliance training performances and ethics surveys
• “Workplace Civility” cases (e.g., adherence to the code of conduct)

KPMG perspective

To build, operationalize, and sustain a strong ethics and compliance culture, an organization must adhere to the foundational elements of driving trust. Trust is built on consistent, predictable action in the moments that matter—like keeping data safe, using ethical business practices, complying with regulations, and partnering with credible third parties. KPMG’s Trusted framework sets forth the following six elements that companies can embed into their business to earn and sustain the trust of stakeholders:

• Purpose and Strategy
• Culture
• Leadership and Management
• Governance and Structure
• Systems and Processes
• Products, Services, and Operations

A strong ethics and culture of compliance is one that fosters and celebrates doing the right thing—an environment that constantly looks to enhance integrity and earn/maintain trust.