Annual Reviews and Compliance’s Role Session 2: Annual Reviews of Employee Appraisals

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Bailey Naples, CCEP
Manager of Compliance and Internal Audit

This is a three series of blogs that covers Compliance’s role in annual reviews of policies and procedures, employee appraisals, and conflict of interest forms. The second in the series discusses annual reviews of employee appraisals.

One of the first companies I worked at out of college tied our compliance trainings to our annual employee appraisals. This wasn’t directly communicated to employees unless we were delinquent with the trainings. I always felt that should have been communicated better to new hires. It would have emphasized to us the value the company was putting on compliance. While the trainings told us everything we should do, the actions behind the scenes would have meant more.

Compliance needs to be a part of the annual employee reviews and it needs to be appropriately communicated. Clearly trainings should be tied to the employee’s annual review, but so should their compliance with our policies and procedures. Does the employee turn in their expense reports on time? Does the employee submit their time sheets when they are due? Does the employee follow your organization’s badge policy? All these items matter. Billing won’t have accurate accounts if the employee is delayed with their expenses or time sheets. If employees are letting anyone in off the street, even to be polite by holding open the door, equipment or information could be stolen.

Compliance should also be checking that annual employee reviews are indeed occurring annually, or at least relatively annually. Without timely feedback—and really feedback should be occurring more frequently than annually—employees won’t improve as efficiently as they could. This is a detriment to the employee and to the organization. While an employer would clearly address a problematic employee, they might not discuss areas of improvement for other employees until the employee’s appraisal. An example might be an employee who is rude to vendors will be promptly addressed, but an employee who is simply cold to vendors might not be told otherwise until their appraisal. This is why it is important to have appraisals at least annually, to address areas of improvement.

Employees’ appraisals should also have measurable data to compare year over year. If the reviews are subjective in nature, the employee may find themselves spinning in place with similar comments year after year with no measurement for improvement. This could create resentment in the process and cause turnover for employees looking to grow themselves.

The Compliance Department should work with the Human Resources Department to design a measurable, all-inclusive, annual Employee appraisal.

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