Checklist to Improve Compliance

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 I have devoted my summer of governance tips to talking about compliance. I have designed an acronym to help us achieve the goals that have been set by our organizations. The acronym is COMPLY.

C= communicate the policies, 

O= observe behaviour to determine compliance. 

M= measure the compliance. 

P= prevent misbehaviour or provide penalties for bad behaviour. 

L= leadership also known as tone at the top

Y = you can make a difference

Now that we have covered all of that, I want to provide a short checklist to get started and see if you can improve compliance in your organization. Here are the four steps:

· First - Identify all of your policies

· Second- Identify how you are communicating the policies

· Third – Observe and measure compliance, including at the leadership level

· Fourth – Decide if you need to establish either preventive measures or penalties to improve compliance and implement the changes

If you are following COMPLY in your organization, I believe you will see an improvement in your stakeholders following the policies. This should make it easier for the organization to achieve their goals.

 I have devoted my governance tips this summer to talking about compliance. I have designed an acronym to help us achieve the goals that have been set by our organizations. The acronym is COMPLY. I have already talked about:

C= communicate the policies, 

O= observe behaviour to determine compliance. 

M= measure the compliance. 

P= prevent misbehaviour or provide penalties for bad behaviour. 

L= leadership also known as tone at the top

This week I am talking about Y =you.

There are not a lot of words that start with Y.

What can you do to improve compliance? Everyone  in an organization needs to follow the policies and the procedures. Each person has an opportunity to show the others that they honor the goals of the organization by following the rules. You can make a difference.

Y can also stand for YAY! We are doing all we can to follow the rules, to make our organization successful. Good for us. 

I have devoted my governance tips this summer to talking about compliance. I have designed an acronym to help us achieve the goals that have been set by our organizations. The acronym is COMPLY. I have already talked about:

C= communicate the policies, 

O= observe behaviour to determine compliance. 

M= measure the compliance. 

P= prevent misbehaviour or provide penalties for bad behaviour. 

This week I am talking about L.

L= leadership – tone at the top. 

How many times have we heard that the bosses don’t follow the rules so why should anyone else? If parents don’t model the correct behavior, then the children will be rule breakers as well. 

When I am auditing an organization, one of the items I am required to document is management and board integrity. The old saying “Do as I say, not as I do” does not work. The leaders of the organization must show that the policies apply to them as well and that they are committed to following them.

If you have leadership adhering to the policies, then you have a much better chance of getting the rest of the stakeholders on board.

I am devoting my governance tips this summer to talking about compliance. I have designed an acronym to help us achieve the goals that have been set by our organizations. The acronym is COMPLY and I have already talked about:

C= communicate the policies, 

O= observe behaviour to determine compliance. 

M= measure the compliance. 

We are up to P and I have two possibilities for P. 

P = prevent and/or penalty 

The friendliest one is prevent. After you observe and measure, you may find that stakeholders are failing to follow a rule. Question - is there any way that you can prevent them from breaking the rule? For example, if you don’t want people opening filing cabinets, then lock them. If you don’t want people walking on the lawn, then put up a fence. That is prevention.

Each policy should have a penalty for non-compliance, if you are serious about compliance. Example - If a board member does not attend meetings, then what will happen? If employees are always late for work – are there consequence? The penalties for non-compliance should be established when you first adopt the policy.

We care about the P in COMPLY because if there are no consequences for failing to follow a policy, then you will not have compliance with the policy.

I often ponder the question, how do we get people to follow the rules? I see this type of challenge in both my work as an accountant and when I am doing governance training. This tip is the third in a series that will address the question, how we get compliance with the rules? I have created a checklist that spells Comply and today I will talk about what makes up the M.

C= communicate

O= observe

M= measure

How can we measure whether or not our stakeholders are following the rules? Pick a board policy such as, all board members must attend all meetings. We can measure this by taking attendance at each meeting and tracking attendance by board member. Once we have a measurement, we can determine if we have any areas of non-compliance. That is an easy policy. 

What about conflict of interest? How do we measure if a board member is in a conflict situation? This is a trickier thing to do as we have to figure out all the possibilities and see if we can get the information. Do we ask board members to disclose all of their business interests and the names of their immediate family?  We would do this if we are serious about getting compliance with our conflict of interest policy?

Organizations need to consider each of their policies and see how they are: communicating the policy, if they are observing the behaviour of the stakeholders and how they are measuring the results. 

Stay tuned for the rest of the acronym.