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A Culture, Not a Programme

Much has been written about what constitutes an effective compliance program. Many of these naturally hinge on what your respective regulators consider to be necessary elements of a compliance program. Another popular source of guidance comes from Chapter 8 of the U.S. Sentencing Guidelines for Organizations. These components form the keystone of most companies’ approach to compliance because they are objectively verifiable and easily quantified. Having all these components in place will get you a compliance program (and probably satisfy your regulators, if that is your aim) but this may not be sufficient to establish a culture of compliance. A compliance culture is where the management and all the employees share the common belief, value or goal that doing the right thing, even when no one is looking is an important part of what defines the organisation. This belief underpins all the actions and business decisions of the company and its management and defines the way it operates, including how it deals with its third parties, employees and customers. It becomes part of the company's mores and norms such that it drives high performance the right way.