4 Words You Need to Know in 2019

Mobile. Operationalization. Accessibility. Accountability. Expect to hear those words often in 2019 if you work in ethics, risk and compliance.

As digitization of the world continues unabated, companies are working to deliver their products and services in ways that allow people to access them from any device, at any time, wherever they are.

Businesses also must deliver flexibility and on-demand access of messaging and training to their employees, customers and partners.

Two of LRN’s resident experts, Marsha Ershaghi Hames and Susan Divers, share some of their thoughts on what ethics and compliance managers and their teams should be thinking about in the coming year.


Mobilization of communication and information resources to the workforce will become a key integrative component of E&C program strategy in 2019, as the global growth of mobile content consumption has completely shifted the how ethics and compliance practitioners are reshaping their programming, says Ershaghi Hames, LRN’s managing director of strategy and development.

“Mobile content access cuts across functional and geographic verticals, driving the buzz of workforce engagement,” while supporting the workforce in navigating risk in real-time.

“Embedding push notifications and alerts to top-of-mind topic priorities, especially with regional geotags or policy and regulatory changes, will be a game-changer in advancing the pulse of corporate ethical cultures,” said Ershaghi Hames.


Divers, an LRN senior advisor, said she sees no end in 2019 to the ongoing push by regulators to make sure companies have programs that do more than just exist on paper.

For the past six years, U.S. and overseas regulators have increasingly focused on the outcomes and results of corporate ethics and compliance programs, and what those results say about corporate culture, rather than just checking to see if there is a code of conduct, how many employees receive training, whether there are policies, she said.

Regulators’ emphasis on results started with the Resource Guide to the Foreign Corrupt Practices Act published in 2012 by the U.S. Department of Justice and the Securities and Exchange Commission and became more pronounced in the 2017 Questions for Evaluating Corporate Compliance Programs published by DOJ.

The approach was expanded to other misconduct in DOJ’s 2018 Corporate Enforcement Policy Principles, while U.K. enforcement trends also emphasize culture and how an organization’s compliance program actually works in practice, said Divers.

“Regulators want to know if an E&C program is embedded in business operations, and how it does--or doesn’t--influence business decisions within organizations,” she said. “This shift in approach reflects frustration with continued corporate misconduct scandals despite the investment in and extent of compliance programs.”

To ensure your program meets these criteria, Divers says look hard at the extent to which it is integrated into business processes--the same way standard operating procedures for safety or accounting protocols are embedded--rather than serving merely as a legal requirement.

“This emphasis on operationalizing E&C programs will continue to dominate regulators’ approach to compliance and presents new challenges for programs,” said Divers.


Building trust in a workplace--or trying to rebuild it, if that is the case--will be a focal point for organizations next year, said Ershaghi Hames. One of the most visible ways to measure the level of trust is to see how accountable an organization holds everyone from its leaders to rank-and-file employees, as everyone notices when rules only apply to some and not all.

Equipping frontline managers with the training and resources to foster difficult conversations, and developing the skills to stay engaged in the conversation of culture, will make an impact in 2019, she said.

“Organizations are doubling down on investing in driving greater responsibility and accountability of frontline managers in the culture dialogue,” said Ershaghi Hames, adding employees are more likely to report observed misconduct to their direct supervisor when they believe top management is committed to ethics. 

“The headlines in 2018 pointed squarely to the importance of visible accountability at the highest levels of a corporation in building and promoting and ethical, trust based corporate culture,” she said. “Learning how to #Listenup will be a core component of assessing and implementing leadership accountability in 2019.”


Recently Mary Barra, chief executive of General Motors, challenged her company by replacing a 10-page dress code policy with two words--dress appropriately--despite pushback from the GM policy owners.  

C-suite executives increasingly are asking questions about the operation and effectiveness of their organization’s compliance programs, said Divers. And those that take the time to read policies frequently come away highly critical of the lengthy, dense, jargon-laden style of most of them.

“For employees trying to figure out how to comply in real time with their organization’s risk mitigation processes, the policies can be a more of a barrier than a help, and employees that are not English-speaking can face even more difficulty,” she said.

Focusing on the essential values and elements at stake in each policy, and how to comply and get approvals or guidance, is a better, more operationalized approach to compliance, said Divers. as long lists of prohibited actions can obscure the fundamental ethical principles at stake that underpin good behavior.  

“LRN’s research conclusively shows that a values-based approach to compliance helps inspire employees to ‘live’ the rules,” she said. “Investing in making complex policies clear and easy to navigate is a good way to increase the effectiveness of your compliance program, and to operationalize it.”

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