Compliance is a subject which is often met with fear. Here Barbara Lustenberger, Infront's Associate Director of Legal and Compliance, talks about how we're overcoming that challenge.
The general reaction you get when talking about compliance is usually an eye-roll. People find compliance an annoyance and my key findings after working in the sector for five years is that this dislike comes from fear. They are afraid of it. Compliance still has a reputation of preventing employees from conducting business. But in fact, it prevents you from conducting shady and illegal business that could ultimately have a damaging effect for the company and those who are compliant.
It’s important to view a good compliance as a tool that can today give an organization a competitive advantage. The world has changed, with companies needing to be more transparent about the way they conduct business. There is a necessity to ensure everyone understands that integrity wins. Always.
I see it as one of my major tasks to make colleagues feel comfortable with our Compliance Management System and to make them understand what it actually contains. I am convinced that education gives us the best chance to properly implement a Compliance Management System and gain buy-in from all employees to follow the set rules and procedures.
In terms of training and communication, we use several measures in order to achieve this goal: first, we make an introduction presentation with all new employees and secondly, each employee has to complete an online training on an annual basis dedicated to our Compliance Management System. But as online training is time consuming and the introduction presentation is one of many items a new employee has to cross off their list during their first days at Infront, those two measures are simply not sufficient to help embed a positive perception of compliance.
It was this challenge that led to the first compliance week two years ago, with the support of our CEO, Philippe Blatter. This is one week fully dedicated to topics related to our Compliance Management System. In 2015, we implemented the Compliance Week only at our headquarters in Zug in an effort to see, how our colleagues react and what the feedback and impact would be on the single communication measures.
We used posters, stickers with the compliance hotline number on each phone, infographics and even cupcakes decorated with red flags to inform about red flags when selecting an associated person.
Central to the whole campaign were four key objectives:
- AWARENESS: The messages needed to strengthen the general awareness regarding all subjects and issues related to Infront’s Compliance Management System.
- POSITIVE PERCEPTION: The communication measures had to be entertaining to ensure staff related compliance to a positive feeling instead of the antipathy that is usually expressed when speaking about compliance.
- MOTIVATION: The attention of the staff shall be gained with funny, surprising, provoking but still serious actions and shall reinforce Infront’s employees' engagement to a behavior that is in line with Infront’s internal guidelines and the Code of Conduct.
- TRAINING: The Compliance Week shall enable the staff to acquire additional knowledge and behavioral skills whenever they face a compliance-relevant situation.
We were all impressed by the positive reaction and feedback we received. As none of the communication measures asked mandatory participation, there was a concern that people would ignore or not even notice them. But the opposite happened. The end of the week saw us host a voluntary quiz on the compliance week and more than 85% of the staff participated.
In 2016, as a second phase, we rolled the Compliance Week out across almost all of Infront’s subsidiaries. It was a linguistic and logistical challenge but in the end, the week happened everywhere around the world with positive feedback throughout.
As a follow-on the Compliance Week has had a long term effect, with the Compliance Desk receiving more questions as a result of a raised awareness on the dangers. In general, I really feel that we were able to make compliance more comprehensible for everyone and as a consequence to reduce the negative perception of it.
We have just completed our second Compliance Week, focused on five topics of our Gifts & Hospitality Guideline. The aim is to point out more detailed regulations, facts and figures that all our colleagues need to be aware of in case they offer or receive a gift and/or an invitation.
There was added pressure considering the success of the first week. How could we maintain the level of entertainment, surprise and still not overload the week? What new communication measures could we use? Several brainstorming sessions were necessary, but we eventually defined a concept that bridges to the first Compliance Week whilst maintaining a new look. We obviously want to keep a lot of what happened under wraps as the Compliance Week will be rolled out again in 2018 for our subsidiaries, but I can say that our week included food and fun examples whilst highlighting an important message each day.
It is too early to say how this second Compliance Week was appreciated but I hope that with every communication and training measure we make, we are able to eliminate the negative perception of compliance a little bit more and to convince our colleagues of the advantages such system can bring along.