Compliance When Nobody is Watching



Margaret C. Scavotto, JD, CHC
President, Management Performance Associates

Everyone knows an effective compliance program needs policies, training, leaders, audits, reporting, investigations, corrective action and discipline. You probably already have these elements in place.

You have policies and training to help your employees do the right thing.

You have audits to verify that your employees are following compliance policies (and doing the right thing).

You have a compliance hotline or other reporting mechanism to find out when employees aren’t doing the right thing. And when that happens, you use your investigations, discipline and corrective action policies.

Many of us put these crucial compliance elements in place, cross our fingers, and hope our employees are doing the right thing.

But how do we motivate employees to do the right thing when nobody is watching? After all, most of the time, nobody is watching. And isn’t the purpose of compliance to help employees do the right thing – whether somebody is watching or not?

Policies, annual training, audits and a reporting mechanism are a good start. They are essential. But they are not enough to motivate staff to do the right thing all the time. Your challenge as a Compliance Officer is to make compliance part of daily life for your team. How can we help employees understand compliance every day?

Meet employees where they are. Incorporate helpful compliance reminders into their workflow. Would a shift-change chat work? Flyers in the bathroom stalls? (There’s nothing else to read in there….) Does the Compliance Officer walk the halls and take a couple of minutes to go over basic compliance concepts with staff? What about displaying short compliance messages on a digital photo frame, or compliance videos on an iPad? Training does not have to be an in-service to be effective.

In the era of social media, infotainment and information overload, compliance has to make some noise. Think outside the box for ways to keep compliance top-of-mind, and help staff do the right thing when nobody is watching.


  1. You are spot on for suggesting compliance people walk the halls and talk with the workers. I think the most under-rated tool for an effective compliance program is listening. Listen to the workers. Listen to the field managers. Listen to customers. If you want to know what is going on, learn to listen. If you do that seriously and sincerely, your people will get the message. If you listen, you will then know what is happening, even when you are not watching.

    Cheers, Joe

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