So, you’ve got a global compliance program. But, what do you do when a local team says, “That doesn’t really work here” or “We think it would be better if it were changed to something else for us”?
Kristy Grant-Hart, CEO of Spark Compliance Consulting recommends keeping your values the same wherever you operate. Values are typically based on universal ideas. They and your code of conduct should remain constant wherever possible.
Communications from the CEO and leadership should also be the same everywhere. You don’t want the CEO saying one thing in one country and something else in another.
Categories used for reporting and investigations should also be the same everywhere, otherwise it will be difficult, if not impossible, to track where the issues are. Similarly, root cause analysis and risk assessment methodology must be the same globally.
So where can you localize? She recommends looking at areas such as gifts and hospitalities. What’s reasonable in one region may not be in the other.
Look also at employment practices. Having a policy of non-discrimination is good, but in some regions there may be requirements to hire certain indigenous groups.
To avoid confusion, she advises defaulting to one policy wherever possible, and be sure to have a version control process in place. You don’t want one office to still be operating under an old policy.
Listen in to learn more about how to make thoughtful localization decisions, how to get honest feedback locally, and what to do about facilitation payments.