A strong compliance and ethics program must be instilled across your entire organization in order to a) prevent non-compliant conduct on any level and, b) detect and deter such behavior before it becomes an issue for your business.
Simply having compliance policies is not enough. Employees and managers are not likely to always refer back to the manual before making a decision that may ultimately lead to non-compliance. Therefore, having a working knowledge of compliance laws and requirements is absolutely paramount across the entire enterprise.
Although Human Resources is considered to be the subject matter expert for employment laws throughout the company, HR has a critical role in establishing a compliance program to educate other decision-makers throughout the organization. In doing so, the job in maintaining compliance and preventing non-compliant behavior becomes somewhat easier.
Here are some tips on how to create and maintain an effective compliance program:
Establish written standards, policies and procedures.
Appoint an independent senior compliance authority within the company, outside of Human Resources. An example would be the COO or CFO. Some organizations leverage their Legal counsel as a senior compliance authority.
Continue education and training, not only for HR, but also for senior management and all employees
Conduct self-audits and monitoring. Execute mock scenarios to verify policies are understood and followed.
Evaluate program effectiveness using surveys and focus groups comprised of management and employees.
Make sure your program contains disciplinary action for misconduct as well as positive incentives for employees who report misconduct.
Communicate process for anonymous and non-anonymous reporting
Adjust policies, processes and training as necessary to maintain a strong program
It is incumbent on HR to maintain their expertise and understanding of compliance regulation through continued training. As compliance is something all organizations must deal with, talk with peers about their programs and initiatives for maintaining compliance. Reach out to your CAI Advice and Resolution Team for guidance on your existing program and how to make improvements.