The ethics and compliance team at the University of Southern California (USC) wanted to revamp their program. Stacy Giwa, Vice President Culture, Ethics and Compliance, and Marisa Hardy, Assistant Director Compliance, explain that they went into the initiative with several overarching goals. They wanted to:
- Bring values and ethics-related behaviors to the compliance program
- Provide reasonable assurance to stakeholders that there are core compliance programs elements in place, no easy task in a large, complex organization
- Be more proactive, and identify gaps, trends and themes so that one part of the organization could learn from another
- Focus on partnership at every phase and build understanding of why a compliance program is important
To make the evolution a success they engaged the compliance and ethics committee to help enhance the university’s program’s standards and framework. As a part of that, they framed out what compliance is responsible for and what belongs to other departments. They also obtained strong leadership support.
The resulting program included an assessment tool that enabled both the team and the individual units of the school to evaluate their elements of the program. They also embraced transparency, letting departments know what information they are capturing and the dashboard they were using.
Findings were reviewed with departments and characterized in a positive way, as opportunities for improvement. Improvements plans were set with 1-3 year timeframes, which set goals, but did so in a less overwhelming way.
Their approach earned them overwhelmingly positive feedback from over 25,000 members of the USC community.
Listen in to learn how they did it and to get ideas for how to successfully evolve your compliance program.