LeClairRyan Attorneys: Corporate Compliance Initiatives Must Start at The Top

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Companies reap huge benefits when CEOs make compliance a top priority for the entire organization, write veteran counselors with the national law firm.

Brian Lansing

The CEO needs to make sure employees at all levels of the organization understand that the brass wants to hear from them

Plenty of CEOs “check the box” on compliance, but companies truly benefit when their CEOs treat compliance in much the same was as Amazon, Apple or Dollar Shave Club obsess about customer service, write veteran LeClairRyan attorneys Brian C. Lansing and Patrick J. Hurd, in a newly posted column in online publication Corporate Compliance Insights.

“Regulated companies need to make sure that compliance permeates the organization,” write the attorneys, both of whom are Senior Counsel in the national law firm’s Richmond, Va., office. “The benefits go beyond risk-management: A true culture of compliance feels open and honest to everyone it touches; it leads to higher morale, easier recruiting and retention, happier customers and, ultimately, higher productivity.”

That might sound like a stretch. But in the column (“Five Strategies to Infuse Compliance Companywide”), the attorneys ask readers to contemplate what it would feel like to work at a company scandalized by endless sexual harassment claims or embroiled in accusations of “Enron accounting.” This all starts, they write, with the CEO.

The column offers five tips for building a culture of compliance: set the tone; train your people; build trust; be accessible; and act quickly.

The CEO should see all processes in the organization as opportunities to further the company’s culture of compliance, they advise. “When it comes to setting the tone, remember that actions matter much more than words (which certainly matter, too). When the CEO makes a visible, daily commitment to compliance, it is easy for everyone else in the organization to follow suit,” Lansing and Hurd write.

Like all other job responsibilities, employees must also be carefully trained in compliance. It starts with having a Code of Conduct, issuing copies to all employees and posting it on the company’s intranet, they write. “Consider also posting the Code on your outward-facing website to demonstrate your culture of compliance to external stakeholders,” the attorneys suggest.

As the company trains and retrains its employees, the CEO should make sure everyone understands that compliance-related policies have the force of “law”—with serious consequences for violations. “Take the training yourself, ensure your executive leadership team does, too, and take it seriously,” write Lansing and Hurd. “Doing so sets the example for all employees to follow (remember, tone starts at the top).”

The column also includes several suggestions on how to build trust between the CEO and Chief Compliance Officer, including the CEO initiating “the talk”—a freewheeling discussion about questions like how to handle incident responses, or what the CEO wants with respect to the frequency of compliance-related communications and the level of detail.

Indeed, the attorneys write, the CEO should make sure the CCO and board have an open line for routine reporting and the regular exchange of information about goals, policies, processes and internal investigations. “The CEO needs to make sure employees at all levels of the organization understand that the brass wants to hear from them,” the attorneys write, noting that an anonymous, monitored compliance hotline can make “employees feel they are a valued part of the company’s compliance efforts.”

Lastly, the column emphasizes the need for speed: If a compliance issue emerges, the CEO should never wait and hope it goes away, write Lansing and Hurd: “Decision paralysis can be devastating. It is better to act decisively on the recommendations of the CCO, one way or another. In order for CEOs to get the information they need to act swiftly, they need to make sure all parties understand they can ‘handle the truth.’ ”

In today’s highly competitive environment, it is easy to feel that “now is not a good time” to focus on regulatory compliance. But in the conclusion to the piece, Lansing and Hurd stress that CEOs cannot afford to be consumed by things like mergers and acquisitions, sales slumps or factory closures. Rather, they have to multitask and keep compliance on their radar screens.

The full column is available at: http://www.corporatecomplianceinsights.com/5-strategies-infuse-compliance-companywide/

About LeClairRyan
As a trusted advisor, LeClairRyan provides business counsel and client representation in corporate law and litigation. In this role, the firm applies its knowledge, insight and skill to help clients achieve their business objectives while managing and minimizing their legal risks, difficulties and expenses. With offices from coast to coast, the firm represents a wide variety of clients nationwide. For more information about LeClairRyan, visit http://www.leclairryan.com.

Press Contacts: At Parness & Associates Public Relations, Bill Parness, (732) 290-0121, bparness(at)parnesspr.com or Lisa Kreda, lkreda(at)parnesspr.com

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