Fairwords Weekly: Creating a Culture of Compliance in the Workplace
March 17, 2022
Fairwords Weekly: Creating a Culture of Compliance in the Workplace
March 17, 2022
“Although we understand the costs that enforcement actions can place on shareholders and others, our responsibility is to incentivize responsible corporate citizenship, a culture of compliance and a sense of accountability.”
— Lisa Monaco, United States Deputy Attorney General
Corporate compliance can be daunting and challenging to get right, but it is vital to an organization’s long-term success and overall culture. While most organizations have programs and a code of ethics to ensure their business activities and communications remain compliant, the Department of Justice has clearly indicated that they expect companies to walk the walk. The latest guidelines reflect this. Efforts must go beyond creating programs and materials. Organizations need to weave compliance into the company culture itself, driven by leadership. This week, we explore the importance of workplace culture in relation to compliance.
US DOJ Emphasizes Importance of Corporate Culture
A few months ago, U.S. Deputy Attorney General Lisa Monaco gave a speech highlighting several important changes in how the US Department of Justice (DOJ) will pursue corporate crime during the Biden Administration. One theme that rose to the top was the importance of corporate culture in compliance. The speech referenced culture six times, suggesting a renewed commitment to focusing on corporate culture. Monaco also noted that companies serve their shareholders by proactively implementing compliance functions and spending resources to anticipate problems.
Driving Cultural Change to Reduce Corporate Risk: Lessons Learned From the Field
The DOJ has long believed that company culture plays a critical role in compliance. The Department’s guidelines for evaluating corporate ethics and compliance programs expressly direct prosecutors to “assess whether the company has established policies and procedures that incorporate the culture of compliance into its day-to-day operations.” Many companies believe that they have a culture of integrity and compliance, but research indicates that it’s not enough to demand a positive culture; they must take meaningful steps to drive that culture. Here are a few things organizations possess that indicate a true culture of compliance.
Fulfill and Exceed DOJ Guidelines
The DOJ has made it clear in the latest guidelines that compliance needs to be taken seriously by organizations. Simply having a compliance program to ‘check the box’ is not enough—it must work. Compliance is a business process that must be measured, managed, and improved. Programs must be dynamic and updated to align with modern circumstances. Here is a resource that lists some DOJ guidelines and how Fairwords can help fulfill and exceed DOJ requirements.