Compliance Culture - Akhilesh Dooblad

Culture

Culture is define as “the way of life”. Similarly, compliance culture is define as ethical way to do business in daily life. Being a Compliance Officer (CO), the latter must ensure that from the board of directors to the most junior staff, everybody in a company should be compliant. The compliance culture start with the team.

In order a company may build a foundation for a culture of compliance, the following may be the way:

Leadership
Alignment of staff to the culture
Training and testing
Values
Rewards for keeping compliance culture
Technology

Leadership

Simple definition, leadership is the ability of any institution to influence and guide others in the organisation. It is not necessary for managers or senior managers that require to be the leader. “A leader is not necessarily a manager”. A leader have the following abilities:

Stay focus
Mindful
Consistent
Strategies
Teachable
Admit when wrong (most important)

Alignment of staff to the culture

The compliance culture start with “YOU”. All staff in a company should be aware of the compliance culture. A company usually should have its compliance manual and the manual must be readily available to all staff in the company. The compliance manual must be considered as the sacred book of the company and it should be abide by everybody at all point in time during business hours.

It is always noted that the meaning of compliance words are interpreted differently. In the case of doubts, the staff should always approach the CO of the company and request a proper interpretation of the points which are difficult to understand. The request for proper interpretation may be in any form, that is, either verbal or written. A written request is usually recommended than any other request. The written request is seem to be more appropriate as in case of any misinterpretation, the CO take the responsibility of interpretation of the manual (evidence). Obtaining written confirmation of the interpretation, it imply that the staff are in line to the manual.

Training and Testing

Training on the compliance culture is an important part of compliance culture. Training allows the staff of the company to be aligned with the compliance culture. The training are evidence that all staff are being explained the interpretation of the compliance manual. The training will create awareness among staff and at the same time, queries regarding to any issues not understood or any misinterpretation of the compliance may be clarified. It is recommended that the training on compliance is conducted on continuous basis and the culture should be part of the induction training for new staff.

The company, to ensure that all staff are aligned to the compliance culture, testing of knowledge is required. To evidence that all staff are aligned, the company should test all staff on the compliance culture. The test may be written test, quiz or practical test. Practical test may include the help of white hat hacker who may create a phishing expedition or creation of Suspicious Transaction or penetrate in the company’s software to see the action of the staff and the way forward of the staff action.

Values

Values in simple terms means things that are important in the day – to – day of individual. Similarly, in company, values are the day – to – day ways to do business. To enhance the company’s values, companies usually uses acronyms such as CUPS values such as C = Commitment, U = United, P = Pioneering and S = Similarity across staff. While being compliant, we require values in order we may align all staff in simple ways. In addition, it is simpler for staff to adopt value than culture. Values is part of culture and it is not culture and values are much simple to adopt. A few values that are inscribe in the compliance manual and requires to be abide are topics such as dress code, trustworthiness, commitment, integrity, innovation and many others.

Rewards for being compliant

Rewards are usually incentives provided to staff for being compliant or being ethical or upholding the values of the company. The rewards could be anything simple or bigger. Simple is classified rewards such as certificate of recognition, vouchers, promotions, increment in salary or anything simple which make the staff motivated. On the other hands, there are rewards such as bigger increments in salary, promotions at another level in the company or month(s) of bonus. The incentives shall encourage to be committed to the compliance of the company.