The age-old question of “if a tree falls in the forest and no one is there, does it make a sound?” may not seem applicable to compliance but I assure you it is. If staff report a compliance issue and no one hears them, why even take the time to make the report?
One of the bedrock principles of an effective compliance program is accessibility. Good organizations promote the ability to access the program either through direct contact with the compliance officer, or by tapping into a trusted reporting mechanism. If stakeholders don’t know how to access the compliance program, the program is likely just a hollow set of policies and not at all effective.
A major factor in whether employees will access the compliance program is trust. If staff fear retaliation, or they believe nothing will happen if they bring a concern forward, they simply won’t tap into the program, and the organization will not know of potential issues and risks. For a compliance program to be effective, people have to trust it, and people have to access it.
Having a well drafted written procedure for how all matters brought forward are investigated and handled ensures the program does what it says it will do, and builds trust in the program. Staff pay close attention, and they want to know their voice is heard. We recommend organizations publicize the hotline number and the non-retaliation policy. Post the number in the employee breakroom, in the elevator, heck, even in the employee bathroom (everyone goes there!), so every stakeholder is aware the disclosure program exists and knows how to access the program.
When calls come into the hotline, or concerns are brought forward, it is an indication that people know how to access the compliance program and that they trust their voice will be heard.
Most business leaders get frustrated when employees don’t do the right thing. You shouldn’t have to convince people to do what is right. MCA builds a compliance program and a culture where employees do the right thing, the right way, at the right time so you can focus on taking care of the people you serve.
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Midwest Compliance Associates