By Deann M. Baker, CHC, CCEP, CHRC
From Y-Comply, a service of the Society of Corporate Compliance & Ethics.
Maya Angelou, an American author, once said, “When you know better, you do better.” This is also the philosophy of organizations when assigning written standards for the workforce to review and acknowledge.
Written standards include the Standards for Business Conduct (SBC) (some call it a Code of Conduct) and policies and procedures. The SBC typically outlines the organization’s compliance and ethics program structure; its purpose and resources; the organization’s mission, vision, and goals; and some of the organization’s higher risk areas that are further addressed in its policies and procedures.
Establishing and communicating written standards is one of the elements defined by the Federal Sentencing Guidelines (FSG) for effective compliance and ethics programs. The FSG states that organizations must demonstrate due diligence and promote a culture that encourages ethical conduct by defining policies and procedures to prevent and detect criminal conduct, by taking reasonable steps to communicate it’s policies periodically and in a practical manner, by conducting effective training programs, and by disseminating the information to appropriate individuals based on their roles and responsibilities.
What can happen if an organization’s workforce doesn’t review and acknowledge the assigned standards? If an organization comes under scrutiny, it may be required to demonstrate that it reasonably communicated to its workforce its standards regarding a risk area. If the tracking reports demonstrate that there was poor participation in the review and acknowledgment of the assigned standards, then the organization may not meet this element of compliance defined by the FSG. This could lead to consequences for the organization.
What have organizations done to encourage employees to participate in the review and acknowledgement of standards? Many organizations have implemented incentives, such as tying the completion of the review and acknowledgment of assigned standards to the annual performance review. If workforce members do not complete the assignment within the timeframe defined, they will not be eligible to receive a “meets performance objectives” review and will not receive a raise. Incentives help emphasize the importance of an area. It’s most often true that what gets measured gets done.
What are the benefits of reviewing and acknowledging the organization’s standards?
It empowers workforce members with knowledge regarding how to meet requirements, how to identify potential or actual risks, and how to know what resources are available to assist them. Therefore, they are able to be more successful in their roles and help the organization meet its mission. Completing the review of the organization’s assigned standards helps everyone to know better, so they can all do better.
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