Wednesday, June 13, 2018

The Compliance Complex...have we cracked the code?

The Compliance Complex...have we cracked the code?
Insights from Christopher Annand, Director of Global Ethics & Compliance, Cargill

The other week I had the pleasure of meeting with Christopher Annand, Director of Global Ethics and Compliance at Cargill. Christopher is a compliance professional who has over 15 years of experience in the industry, and specializes in the development and delivery of compliance education and outreach programs at what is the largest privately owned company in the United States, and one of the largest in the world. Cargill operates in 70 countries spanning the globe and is comprised of 150,000 employees, all
working to drive the growth and success of the global food and agriculture enterprise. Christopher has the task of overseeing the governance and control factors in the compliance program, as well as managing the global teams and business partners. In short, he makes sure employees are keeping up with the Cargill standards. Sound easy? Not in the slightest. Compliance is one of the most difficult and complex jobs to work in because managing people has proven time and time again to be the hardest task on earth. When it comes to behavioral is said to be near impossible.

Christopher explained how from the very beginning back in 1865, one of the first promises founder William Cargill made was, “my word is as good as my bond”. From there on out, they were committed to sticking to these 7 guiding principles, which Christopher listed off the top of his head.
  1. We obey the law.
  2. We conduct our business with integrity.
  3. We keep accurate and honest records.
  4. We honor our business obligations.
  5. We treat people with dignity and respect.
  6. We protect Cargill’s information, assets, and interests.
  7. We are committed to being a responsible global citizen.

Cargill holds their employees to stringent operational and workplace standards, but when it comes to what works most effectively to ensure employees understand and comply...well, the devil is in the details. Workplace policy and corporate culture is something every company is focusing on making a top priority, but unfortunately it's because we have seen consequences have become too big to bare. Just last week Starbucks’ CEO Kevin Johnson spent upwards of $12M to shut down all locations and hold a nationwide racial-bias training following an incident where a staff member called the police on two black men in a Philadelphia Starbucks. Wells Fargo has come a long way in realizing the importance of having good culture alongside a trusted reputation, after their recent incident where over 3,000 employees were found to have opened fake bank accounts in order to make monthly quotas. Starbucks and Wells Fargo serve as examples of what happens when employees fall away from an organization’s core values. What could they have done differently?

At Washington D.C.’s Compliance Week 2018, Christopher shared his views on his use of data, a closely related topic buzzing amongst all businesses these days correlating directly to information about behavior. Christopher explained, “he can glean plenty from training data--how many people have completed it, how much time they spent in training, how they received their training--but that doesn’t necessarily speak to the effectiveness of the training to sway how people behave”. In my research about compliance, I have found the same consensus across the board. Systems and softwares have done a phenomenal job of collecting information and categorizing it into data, but when it comes to applying that data to see and measure real results in the workplace, it takes an even deeper level of strategic integration. 

Compliance officials like Christopher Annand are working diligently to “crack the code” for what works best to prevent non-compliance incidents from happening. Companies are now taking more proactive measures to mitigate their exposure, but in a world that is more connected, and therefore more vulnerable than ever before, is it enough? The holy grail lies in what changes employee perception and overcomes resistance to compliance in order to achieve higher levels safety, ethics and morale, and productivity in the workplace. “The drip method is good and works effectively, and the visual animations I have been creating seem to really stick with employees, but behavior change is a big topic and I haven’t cracked it yet.” Welcome to the compliance complex. With every challenge comes more avenues for innovation. I think we are onto something, but we have our work cut out for us.

Written by Charlotte Whiteman - Defense Mitigation & Remediation Advisor

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