Effective communications: notes from the field

The area of other C&E communications (meaning other than training) covers a lot of ground. It is also utterly indispensable to  C&E.

Certainly it matters to the Department of Justice (the DOJ).  Notably, in 2012 DOJ declined to prosecute a prominent investment bank for FCPA violations due, in part, to the strong anti-corruption communications plan the bank had put in place prior to the offense at issue. And, in the 2020 C&E program evaluation standards DOJ emphasized the importance of communications.

Given how vast this territory is  I can’t catalogue all the good (and not-so-good) practices from my 30 years in the field.  But hopefully some of these “field notes” will be useful to practitioners, particularly those who are new to C&E.

Governance

For many reasons it may be important to have a C&E communications committee. Such a committee can help both in keeping the communications current and in disseminating them.     A typical approach regarding membership would be to have the committee co-chaired by the CECO and a high-ranking person in HR – with others as associate members or just as-needed attendees.

Communications plans

Companies should have written compliance communications plans. Such a plan typically covers anywhere from one year to three years, with longer being generally better for various reasons.

Such a plan will typically list by month the communications to be delivered; who is to receive the communication – by position, location, etc.; who is in charge of preparing/acquiring  and delivering the communication; and any other pertinent requirements or impediments (such as the need for translations).

Types of communication

One of the most common forms of communication is to have a senior manager speak to employees at a town hall or other meeting about the importance of C&E to the company. When done right this can be a very effective way of setting the “tone at the top.”  And, when “cascaded” downward – i.e., where managers deliver the message to their subordinates,  – it can be a highly effective means of communication.

Another form of C&E communication is sending an email to all or some employees. This can come from senior managers or compliance personnel. The former have the advantage of “clout,” which is obviously important.  The advantage of the latter is that it can serve as a reminder about the availability of the C&E department, which some employees tend to forget.

Other vehicles for C&E communications include newsletters, intranet sites, internal TV networks, posters and  computer screens that can be locked where an employee has not taken their required training.

Finally, companies should consider requiring that all meetings begin with an “ethics moment.”  These can be combined with “safety moments,” where applicable.

Strategies

For some topics a single communication is not enough. For those instances one should design and deploy a C&E marketing campaign.

Another approach is to package key company documents (such as the code of conduct and the speak-up policy) for distribution to managers as a C&E “toolkit.”

Timing

Companies should consider deploying “just-in-time” communications, issuing relevant communications at the “point of risk.”  See this post  

Metrics and self assessment

A prevalent form of metric of communications is the frequency of receipt of communications by employees (i.e., the number of views of a compliance article, newsletter, etc.)  A related metric is the number of reports to the concerns line after a speak-up communications campaign.

Also worth considering is surveying employees on what type of company communications they think are most helpful in promoting compliance. This sort of effort may become more important with the passage of time, as “compliance fatigue” sets in.

Like I said, not close to being an exhaustive exploration of this vast topic. But hopefully helpful.

 

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