Enlisting E&C Champions at All Levels of the Business: The E&C Pulse - October 16, 2019

October 16, 2019 Ben DiPietro

Oct. 16, 2019

Enlisting E&C Champions at All Levels of the Business


Two of the tasks that must be accomplished to make your ethics and compliance program more operational are getting the right people into the right roles, both within the E&C department and within the other business units, and through enlisting senior leadership and middle management to be champions of the E&C department and its mission.


These were the topics of discussion during a webinar held last week by Ethics and Compliance Initiative that featured LRN's Dr. Marsha Ershaghi Hames as moderator. The panel included April D. Haynes, senior manager of learning and development at Altria; and two executives from Lonza: Stacey Hanna, general counsel and chief ethics and compliance officer; and Will Simmons, head of global investigations.


"It's about dealing with workforce human capital needs, basic education, communication, relationship building, stakeholder management; learning to listen, work, and collaborate together; and employing strategies to develop a scalable program," said Hames.


Most E&C departments don’t have actual full-time people every site, so Hanna said compliance champion programs are important. Her advice? Be deliberate in choosing people to enlist for this effort.


"Work with HR, work with the business to get the right people to do that function," she said. "The last thing you want to do is promote people representing the compliance department who you then have compliance issues with."


Once champions are identified and enlisted, Hanna said it's vital to establish the proper cadence between the full-time E&C team and the champions, then to set realistic expectations of their roles.


Altria uses compliance committees to drive home communications and education related to organizational culture, with some localization to make sure messages hit and land well, said Haynes.


"I can give them a proposal, say 'This is what we want to do,' and they will help us figure out the best way, how we can best position messaging, and learning and development opportunities, what I call the stickiness," said Haynes. "Those people, those committees, are critical for us having a culture of compliance across the organization."


Another important function these committees fulfill is communicating what is coming in terms of training, and why that training is necessary, so when it's time to actually take the training, it's not the first time employees are hearing of it, said Haynes.


With tone at the top, Hanna said it's important to remember the Department of Justice will look at whether the board and senior management are engaged on ethics and compliance issues, and how they communicate this to the organization.


For reaching middle managers, Lonza uses podcasts to deliver messages from the general manager at each of its regional sites, as this is the person in that location who employees most associate with tone at the top, she said.


Simmons said he finds it helpful when speaking with the board and senior leaders to go beyond what is required under regulations, and to tie the importance of having a strong program with the investigations the company is undertaking.


"That education aspect--this is why we are pushing this out--we have found senior leadership engaged because they, too, want to stop these issues before they happen," he said. "Just saying, 'Do this because the regulators say we should do this,' you need to say why, here’s how it is specific to your function, your group."



                                                                                                            BEN DIPIETRO




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