Effective Communications Strategies for Mitigating Conflict of Interest Risks (Part Two)

by Joel Rogers

(This is the second guest post by Joel Rogers of Kaplan EduNeering on effective conflict of interest compliance communications. His bio and contact information can be found in the first post.)

In our prior discussion about COI messaging I analogized to the practices of product advertisers, on the principle that they have already mastered the techniques necessary to mount a campaign designed to change not only minds and opinions, but behavior.  Just as a marketing campaign uses these techniques to influence how people think and act, a well designed COI communications program will, over time, help employees automatically recognize and avoid COIs; it will become second nature for them to disclose such conflicts as specified by company policy.

There are some key steps to planning such a program that can make it much more manageable than it at first would seem.

First, take the time to identify communications channels that already exist within your company.  This seems obvious but is something that, when overlooked, makes your task seem much larger than it is.  There is already a multiplicity of ways that people in your company receive communications.  These may include newsletters and/or a company magazine, Email, bulletin boards where posters are hung, internal TV Networks, online learning resources (a Learning Management System), lunch rooms and break areas where brochures and table tents can be left, intranet sites, etc.

Second, create some simple messaging around conflicts of interest.  One nice thing about this topic is that it lends itself nicely to hypothetical scenarios.  Then repurpose this message again and again in a variety of formats.  For example:

– Design a couple of simple posters depicting these conflicts scenarios.  Consider running a contest asking employees to respond to the scenarios – what is the conflict and how might it be resolved? Give awards for the best responses.

– Draft an article or two for company publications laying out in simple language the key principles of your conflicts policy, perhaps discussing again the scenarios appearing in the posters.  Consider making one these articles a fictional story.  Good stories will be much more powerful than dryer informational articles.  Republish these articles on your intranet site.

– Repurpose small amounts of key text from the articles into different types of printed media (e.g. brochures).

– Use in-company TV networks to broadcast periodic, brief messages from the CEO discussing the importance of maintaining a corporate ethical culture; use such broadcasts to call out key E&C risks, including COIs (tone-at-the-top still means a lot).

– Repurpose key points from the article text to create a Powerpoint that can be distributed to managers and have them run meetings with their staff specifically on this topic (tone-at-the-middle may mean even more).

– Have your online training provider create mini-online-learning modules, interactive games and other computer-based tools that can supplement your formal online COI training.

– Use images appearing as part of these other tools to create screen savers, intranet advertising, small format print images in the form of quarter page ads in the company magazine, etc.

Once all of your tools are ready to go, begin “dripping” them out over time.  Resist the temptation to push everything out at once, but you certainly may want to increase your exposure during disclosure periods.  Whatever you do, remember that your primary purpose is to put out a consistent message as often as you reasonably can, through as many communications channels as possible, in ways that speak to an audience that learns in very different ways from one another.