By Kristy Grant-Hart
How do you work with Human Resources? Do you have a good relationship? If so, why and how? These are the questions I’ve been asking my compliance friends in a survey I’ve created to get the answers straight from the experts – YOU! I’ll be taking your answers (anonymously of course) and putting them into my presentation at the SCCE Conference in Las Vegas.
What have I found so far that can help us avoid the dreaded turf war with Human Resources? Four answers have emerged.
Define Roles and Responsibilities for Internal Investigations
Turf wars seem to develop out of nowhere during internal investigations. In the ugliest scenarios, HR and Compliance hide information from each other or perform investigations in silos, occasionally duplicating each other’s work. To avoid this from happening, it is best to define your roles and responsibilities for internal investigations before you engage in them. Decide where to keep documents, what templates will be used, and how to determine who will take the lead on the internal investigations at the outset so you don’t run into problems later.
What if you’ve never developed a protocol for internal investigations or tensions are already running high? No problem – set up a meeting to ask them how they think internal investigations will work best. By engaging them in the conversation, you can begin to build a rapport to make decisions together.
2. Agree on How to Share Exit Interview Data
I’ve worked with a number of compliance departments that never see the data from exit interviews. Not only is this information critical for taking the temperature of the culture in the organization, this data can provide invaluable assistance for understanding risk in the organization. Compliance will see exit interview data through a different lens than HR. Where HR might simply see bullying by a manager, compliance may see potential fraud, cover-up, conflicts of interest or broader culture issues which could implicate ethical failure by the manager.
Agree on how you will share exit interview data. Perhaps there are data privacy concerns, so you can get an anonymized version of the data? Maybe you can get a monthly report amalgamating the results? Perhaps HR can add you as a database user so you’re able to access the data without their direct involvement? Exit interview data is key, and you need to have it to do the best job you can in your role.
3. Agree on the Separation of Issues to Handle
In most companies, HR reviews HR issues, but it isn’t always clear where HR issues end and compliance issues begin. For instance, when a conflict of interest involves a romantic relationship between two co-workers, is that an HR issue or a compliance issue? What about a situation where a report of wage and hour violations includes a retaliation compliant in violation of the Code of Conduct?
Agreeing on the separation of issues beforehand will avoid problems when a large issue arises. Try to set up a protocol for determining which issue is the foremost issue if more than one issue is present or overlap occurs. By agreeing early, you’ll stop problems from occurring later.
4. Create a Close-Out Protocol for Whistle-Blower Complaints Relating to HR Issues (which is most of them!)
How many calls to your whistle-blower hotline relate to HR issues? All of them? If your company is like most companies, nearly all of the calls received by the whistle-blower hotline relate to HR issues. From reports of someone smoking in the bathroom to garden-variety I-hate-my-manager calls, the majority of whistle-blower complaints come in regarding HR issues.
If you’ve developed protocols for dealing with these issues, the next step is ensure that you receive information on the disposition of these investigations or have the ability to ensure that these whistle-blower complaints were properly investigated and closed-out. Ideally you’d have access to the final reports to ensure the investigation was handled correctly, but at the very least, you need to be able to verify that the investigation was completed and the case closed.
How else have YOU found to work effectively with HR? Share your answers in the comments!
With a little pre-planning, you can make the corporate schoolyard much more of a playground than a turf war.
Kristy Grant-Hart the author of the book “How to be a Wildly Effective Compliance Officer.” She is CEO of Spark Compliance Consulting and is an adjunct professor at Widener University, teaching Global Compliance and Ethics. She can be found at www.ComplianceKristy.com, @KristyGrantHart and emailed at KristyGH@SparkCompliance.com.
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When I started up the compliance role six years ago at my organization, it quickly became clear that there was a lot of cross-over between the work of compliance and HR. Thus, for the first year, HR and I met on a monthly basis just to ensure we knew who was working on what and to ensure neither felt the other was stepping on their toes.
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