Curbing compliance waste

Legendary merchant John Wanamaker once said: “Half the money I spend on advertising is wasted; the trouble is I don’t know which half.”  C&E officers frequently have a similar feeling.

It will often seem hard to know what parts of a training program are truly necessary, and the same can be said of auditing and other C&E-measures.  But C&E activities aren’t exempted from the same need to be efficient that other business activities have.  Moreover, for various reasons (including, in some companies, the onset of “compliance fatigue”) this imperative seems likely to grow over time.

Often a risk assessment can provide the basis for making programs more efficient, i.e., for painting with a narrow brush.  Particularly helpful in that regard are granular assessments. These seek to determine for:

– which risk areas (e.g., corruption, competition law);

– what “tools” – especially policies, training/communications, auditing/monitoring, defined accountabilities and other process controls, which tend to be the most risk-sensitive tools in the C&E toolbox – should be deployed based on;

– geography, job function, business unit or, in the case of third parties, contractual relationship.

Going through this process won’t enable cuts of half the money you spend on C&E. But for some companies the savings – not just money, but also employee time – should be substantial (particularly in the training area).

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