Compliance 3.0: Leveraging Social Media to Drive a Culture of Compliance. Summary

Transcription

1 Compliance 3.0: Leveraging Social Media to Drive a Culture of Compliance Louis A. Sapirman & Thomas R. Fox September 25-28, 2016 Summary Focus on how the Compliance Team can act as a steward of Corporate Culture. When you know your audience well, communication around corporate culture requires the appropriate tools for your employee base. Social Media can be a very powerful tool As quickly as the world of compliance is changing, the world of technology is changing faster. Compliance Professionals must be comfortable in this world of change to take advantage of opportunities and identify risks 2 How do we view the effectiveness of our Program? One of the most succinct discussions of measuring the effectiveness of a compliance program comes from the FCPA Resource Guide to the U.S. Foreign Corrupt Practices Act. Dun & Bradstreet measures each element of its program through the 10 Hallmarks of Effective Compliance Programs. We then look at each program/tool we intend to use through the lens of how it supports each hallmark. 3 1

2 Building Blocks of an Effective Compliance Program Dun & Bradstreet s Compliance Program Comments 1. Commitment of Senior Management 2. Code of Conduct and Policies 3. Authority, Autonomy & Resources A B C Social Media D E F G H I 4. Risk Assessment 5. Training and Advice 6. Disciplinary Measures 7. Third Party Due Diligence 8. Confidential Reporting and Investigation 9. Continuous Improvement 10. Acquisition Due Diligence and Integration 4 Compliance and Social Media 3.0 Communicate with employees in ways that are accessible, understandable, engaging and inspiring Leverage Social Media in as many ways as possible to drive a culture of compliance: For more sustained communication with the Company s compliance function As a reporting mechanism As a reference tool To stay ahead of your industry curve Celebrate employees through social media to incentivize behavior and celebrate victories in compliance Use analytics to derive insights and measurable analytics especially in times of organizational change - to allow you to proactively plan going forward 5 Branding Our Compliance Program Find the right words that will speak to your employees through your Code of Conduct and company values. At Dun & Bradstreet, we use I Always Do the Right Thing as our compliance brand. It helps tie together sometimes disparate elements of our program and is instantly recognizable to our employees. We include the brand in as many places as possible: Training Communications, including intranet stories The Code of Conduct (named Do the Right Thing ) Give-aways (we have branded pens that we hand out at our events and trainings) On Social Media (#DOTHERIGHTTHING) 6 2

3 Compliance at Dun & Bradstreet Embraces Social Media The challenge to modernize the way we engage with our workforce comes from the top Our CEO, Bob Carrigan, challenged all senior leaders to modernize our relationship with technology leveraging technology as a platform to transforming our company and culture. The Compliance Team embraced this challenge beginning slowly at first, posting photos from some of our global compliance trainings and seeing what appetite existed for social media discussion within our employee base. Even these first posts received dozens of likes from employees around the globe. 7 Chatter, Twitter, Facebook at Work We use both internal and external facing social media to engage with our tech-savvy workforce Internal Salesforce.com Chatter (and soon Facebook at Work for key partners) Communication with employees and key contractors Discussion (easy to follow #DOTHERIGHTTHING) Real-time feedback The office watercooler Chatter-Jams External Twitter Followers include some employees and key third-party providers and customers Following active thinkers in the field of Compliance and Ethics to share the best new thinking Ability for instant communication Auditable 8 A Few Principles for Effective Internal Social Media Brand your posts to make them easily searchable and to create a community (#DOTHERIGHTTHING) Don t be too tentative find topics that will interest your employees. Getting them comfortable talking about compliance and ethics and risk doesn t mean every post needs to start with According to the FCPA. Seed your environment with influencers the more active employees are participating, the stronger your results People love Photos and Graphics Don t forget the great feedback opportunity Social Media represents 9 3

4 Chatter 10 Chatter Jam Sample (for Code of Conduct launch) Objective: To promote conversation about the Code of Conduct, the launch of our new training course and to keep the subject top of mind for employees. What We Do: Compliance team gathers and spends an hour on the computer answering employees questions and discussing key elements and changes in the Code of Conduct. How we Do it: Coordinated Communications (website, social media, etc.) around the time(s) the Chatter Jam is taking place along with seeding the environment with topics that people may want to discuss. How we avoid concerns: Set ground rules and expectations for conduct. For example: Let people know that confidential matters should never be shared in this manner Refer people to the Social Media policy Remind people of how to contact the compliance team directly for individual issues: Hotline/Web reporting address(es) Direct phone numbers. 11 Compliance Chatterjam Sample DATE June 10 June 18 June 18 June 19 ACTIVITY Calendar invite from Louis Sapirman to all team members in Asia Pacific and India (DL China, DL Australia/NZ, DL India, DL Japan, DL Malaysia, DL Singapore, DL Taiwan) message from Louis Sapirman reminding Asia Pacific team members to join the Chatter Chat Spotlight on D&BNet reminding team members to join the Chatter Chat link to calendar invite so team members can easily add the event to their calendar Note from Louis Sapirman to legal team reminding them to participate in the Chatter Chat Moderator/Host: Louis Sapirman Hashtag: #DOTHERIGHTTHING Calendar Invite (June 10): SUBJECT: Come Chat With Us Team, The Compliance team aspires to align with D&B s changing culture to help create a highly engaged, passionate workforce that is energized about refreshing D&B and always doing the right thing. We want to hear from you: What tools do you need to better understand what compliance means to you? What can we do to help you always do the right thing? How does the Compliance team support D&B s global growth strategy? Join me and other members of the Compliance team on Chatter, using #DOTHERIGHTTHING. Need a reminder to participate? Simply add the event to your calendar. <LINK> 12 4

5 Compliance Chatterjam Sample (cont.) Opening Thank you to those of you who participated in Corporate Compliance and Ethics Week. At that time, we shared vignettes to stimulate discussion around Leading with Integrity and Non-retaliation for reporting wrongdoing. If you haven t already, please view these vignettes on Today, I am here with the other members of the Compliance team to chatter in real-time with you and receive your compliance questions and input. But first, some logistics/ground rules: 1. When posting/commenting please remember to use the hashtag #DOTHERIGHTTHING so that you will be heard by us and other participants. 2. Important! If you have a specific compliance matter you would like to discuss, to protect your confidentiality and others, do NOT share it on Chatter. Instead, please contact us anytime at complianceofficer@dnb.com or the D&B Global Compliance Hotline at Here we go! #DOTHERIGHTTHING 13 Compliance Chatterjam Sample (cont.) QUESTIONS Compliance: What does Compliance mean to you? Answer: One definition we use is Always Doing the Right Thing #DOTHERIGHTTHING What tools do you need to better understand what compliance means to you? What can we do to help you always do the right thing? Do you know where to go for help on a compliance matter or question? Ethics and Integrity at D&B Why is creating a culture of integrity and ethics important at D&B? Who owns compliance at D&B? Answer: All, every person is important. Every team member is a representative of the company and an ambassador to our brand and business. How often does Compliance come up in your discussions with your leaders or team members? What improvements in compliance awareness have you seen over the last 2 years? Where is there still room for improvement? What best compliance practices have you seen at other companies/prior employers? What recommendations do you have for engaging team members/raising awareness in your business or market around compliance? 14 Compliance Chatterjam Sample (cont.) Code of Conduct We are working on revamping the company s code of conduct to be more Modern, Global and Outside In Do you have any thoughts/suggestions for how we can make our code of conduct most effective as a guide to team member conduct? Many companies have renamed their codes of conduct (for example, Google has used the phrase Do No Evil ). We are considering giving our Code a more modern name. What new name might resonate with you? General How does the Compliance team support D&B s global growth strategy? Which tool would be most helpful/feel most modern to keep compliance top of mind? -Mobile app for Code of conduct or other compliance policies -Mobile app for compliance training -Mobile app for asking questions or raising concerns Closing We ve had some great interactions and your thoughts and feedback has been greatly appreciated. Unfortunately, we are out of time for now. Please keep the conversation going using #DOTHERIGHTTHING. We ll be looking for your additional input. On behalf of D&B and the Compliance team, thank you! #DOTHERIGHTTHING 15 5

6 Twitter Louis tweets 16 Twitter Louis tweets (cont.) 17 Twitter Louis tweets (cont.) 18 6

7 Twitter Louis re-tweets 19 Twitter Bob Carrigan s Tweets 20 A Few Principles for Effective External Social Media Focus on the Big Picture Let users know you have a broad perspective on your field or expertise Mix in the Personal Be authentic - if you have something personal to say, that will help engage your followers, do it! Don t worry about the numbers The numbers of followers and posts is not nearly as important as the engagement with followers and impact of posts People love Photos and Graphics Follow Louis and Tom! (@LouisCCODNB 21 7

8 Don t lose sight of older technologies (Planes, Trains and Automobiles) Compliance Professionals are at our best when we are able to leverage great business relationships to impact culture. Travel and being with employees in their own space is an invaluable tool to building relationships and connections. The more direct and meaningful relationships you have with people throughout your business, the more likely your programs will take hold and ensure you are driving the right behaviors and changes in your culture. Social Media becomes more effective when you have seeded the environment with great relationships! 22 Louis and Tom s Contact Information Louis A. Sapirman Phone (973) sapirmanl@dnb.com Twitter (@LouisCCODNB) LinkedIn Louis Sapirman ( Thomas R. Fox Phone (832) tfox@tfoxlaw.com Twitter (@tfoxlaw) Follow Tom s blog and podcast at 23 Thank you! 24 8