Compliance Perspectives

By Adam Turteltaub

One of the most provocatively titled sessions at the 2019 SCCE European Compliance and Ethics Institute was “Becoming ‘Invited In’:  Creating Compliance ‘Addicts’ Globally.”

Aversion, not addiction, is more typically associated with compliance, unfortunately, and it made me want to learn more.  So, I asked the two co-presenters to sit down for a podcast to share what they meant by the term.  Nadege Rochel, Global Compliance Manager and Susan Roberts, Chief Compliance Officer of Hollister Incorporated both readily agreed.

A compliance addict, they explained, is someone who does something extra beyond simple compliance.  So, how do you get people to become addicts?  Not surprisingly by rewarding them.  But what may be surprising is how simple a reward it was:  a pin.  It turned out to be both an offer of recognition and a way for the recipient to be recognized by his or her peers as someone with a strong commitment to ethics and compliance.  It also triggered a competitive streak, with others wanting to earn the pin as well.

This simple approach has infused their compliance programs and offers lessons for others seeking to create cultures in which the compliance program is embraced.  As they explain, they did not stop with pins.

At sales meetings they try to schedule lunches and breakfasts with people, and even join in at the end of the day.  There’s a compliance booth where employees can win a ribbon or candy for answering a question correctly.  And, once again, those who wear the ribbon generate interest in those who have not yet earned one.

These techniques, coupled with several other business-team friendly initiatives, have helped the compliance team and program make tremendous strides.

Listen in, even though we can’t give you a pin for doing so.

Note:  Nadege speaks first.

By Adam Turteltaub

Few can look back at a career in compliance and ethics as rich as Alan Yuspeh’s.  He served as the coordinator of the Defense Industry Initiative (DII), Senior Vice President and Chief Ethics and Compliance Officer for HCA Healthcare and as a president of the Health Care Compliance Association.

In a fascinating conversation he shares his experiences and learning from a remarkable career.

In 1986 he began his role with the DII, which includes 50 of the largest defense contractors.  Many of the elements of compliance programs that are commonplace today owe much of their existence to the efforts of DII members:  codes of conduct, compliance training, and hotlines to name a few.

Then in 1997 he joined HCA and moved from the highly-regulated defense arena to the equally regulated healthcare industry.  A great deal of what worked in defense found a place in healthcare as well.

During his time at HCA he developed a compliance program that had three aspects that he felt were particularly valuable and distinctive:

* Having effective local compliance and ethics officers

* The development of Responsible Executives for each area of compliance risk: experts tasked with developing strategies, policies and procedures for mitigating key risk areas

* Energetic compliance reviews processes

Listen in as he explains more about this trio of programs and discusses both micro and macro ethics.

By Adam Turteltaub

Few can look back at a career in compliance and ethics as rich as Alan Yuspeh’s.  He served as the coordinator of the Defense Industry Initiative (DII), Senior Vice President and Chief Ethics and Compliance Officer for HCA Healthcare and as a president of the Health Care Compliance Association.

In a fascinating conversation he shares his experiences and learning from a remarkable career.

In 1986 he began his role with the DII, which includes 50 of the largest defense contractors.  Many of the elements of compliance programs that are commonplace today owe much of their existence to the efforts of DII members:  codes of conduct, compliance training, and hotlines to name a few.

Then in 1997 he joined HCA and moved from the highly-regulated defense arena to the equally regulated healthcare industry.  A great deal of what worked in defense found a place in healthcare as well.

During his time at HCA he developed a compliance program that had three aspects that he felt were particularly valuable and distinctive:

* Having effective local compliance and ethics officers

* The development of Responsible Executives for each area of compliance risk: experts tasked with developing strategies, policies and procedures for mitigating key risk areas

* Energetic compliance reviews processes

Listen in as he explains more about this trio of programs and discusses both micro and macro ethics.

By Adam Turteltaub

For many organizations outsourcing their data management is very desirable.  It can provide a wide range of benefits, including the ability to capitalize on machine learning.

But outsourcing has risks that must be well understood and managed, says Dan Fabbri, the Founder and CEO of Maize Analytics and Assistant Professor of Biomedical Informatics and Computer Science at Vanderbilt University.  In this Compliance Perspectives podcast he explains that there are risk areas to consider and important questions to ask your vendor:  Is the data being held separately or mixed with data of other covered entities?  Will the vendor be using the data for non-contracted purposes?  Who has physical access to the data?  Is the data being accessed by IT and support people located outside the U?  Will the data be stored outside the country?

Understanding the implications of the answers to these questions can make an enormous difference in whether your organization can trust that its data is secure, and exposure of Personal Health Information is unlikely.  It can even protect you from poorly-informed AI affecting your organization.

Listen in to learn more about how you can safeguard your healthcare data more securely.

By Adam Turteltaub

For many organizations outsourcing their data management is very desirable.  It can provide a wide range of benefits, including the ability to capitalize on machine learning.

But outsourcing has risks that must be well understood and managed, says Dan Fabbri, the Founder and CEO of Maize Analytics and Assistant Professor of Biomedical Informatics and Computer Science at Vanderbilt University.  In this Compliance Perspectives podcast he explains that there are risk areas to consider and important questions to ask your vendor:  Is the data being held separately or mixed with data of other covered entities?  Will the vendor be using the data for non-contracted purposes?  Who has physical access to the data?  Is the data being accessed by IT and support people located outside the U?  Will the data be stored outside the country?

Understanding the implications of the answers to these questions can make an enormous difference in whether your organization can trust that its data is secure, and exposure of Personal Health Information is unlikely.  It can even protect you from poorly-informed AI affecting your organization.

Listen in to learn more about how you can safeguard your healthcare data more securely.

By Adam Turteltaub

Compliance is never easy, and it is especially difficult for mid-sized companies in emerging markets.  Many of them operate in countries where there is not even a word in the native language for compliance.

Frank Brown and Anna Kompanek of the Center for International Private Enterprise (CIPE) help companies meet this challenge.  Fortunately, they report in this podcast recorded at the 2019 Compliance and Ethics Institute in Berlin, help is coming.  Large, international businesses that they partner with are encouraging, and often requiring, compliance programs from firms in their supply chain.  This has helped midsized firms see the benefits of investing in compliance, not just as a means to prevent corruption but also as a way to have a more complete risk management system.

At the same time, though, challenges remain.  Some tools offered by risk management vendors are causing confusion.  ISO37001 is sometimes presented as a panacea but can be a trap because of its one size fits all approach, they argue, and many midsized companies don’t have the resources to comply with the standard.

In sum, it’s a challenge, but by listening in to the podcast compliance professionals in large companies will gain a better appreciation of the struggles of their midsized suppliers in developing markets.

By Adam Turteltaub

Compliance is never easy, and it is especially difficult for mid-sized companies in emerging markets.  Many of them operate in countries where there is not even a word in the native language for compliance.

Frank Brown and Anna Kompanek of the Center for International Private Enterprise (CIPE) help companies meet this challenge.  Fortunately, they report in this podcast recorded at the 2019 Compliance and Ethics Institute in Berlin, help is coming.  Large, international businesses that they partner with are encouraging, and often requiring, compliance programs from firms in their supply chain.  This has helped midsized firms see the benefits of investing in compliance, not just as a means to prevent corruption but also as a way to have a more complete risk management system.

At the same time, though, challenges remain.  Some tools offered by risk management vendors are causing confusion.  ISO37001 is sometimes presented as a panacea but can be a trap because of its one size fits all approach, they argue, and many midsized companies don’t have the resources to comply with the standard.

In sum, it’s a challenge, but by listening in to the podcast compliance professionals in large companies will gain a better appreciation of the struggles of their midsized suppliers in developing markets.

By Adam Turteltaub

Each year countries lose billions to corruption, fraud and other compliance failures.

When it comes to stemming this problem, helplines are crucial.  In fact, a study by the Association of Certified Fraud Examiners found that 50% of corruption cases were found through tips from employees.

The challenge for helplines is that there is often an assumption that the calls will come in through a landline.  For much of the world, though, that’s not the case.  Employees are more likely to have mobiles, and that toll-free number isn’t toll-free.  Worse, problems often arise in developing countries where English or other European languages may not be widely spoken.  If your helpline provider doesn’t have a native speaker on premises, it can lead to long delays and awkward three-way calls with a translator.

Paula Davis of Waypoint GRC encourages compliance officers to begin rethinking how they put their helplines to use and explore alternatives such as apps.  She also advises “mystery shopping” the line:  making test calls in multiple languages to see how well the helpline provider handles them.  Also, she suggests asking the provider for abandoned call rates, to see if people are staying on the line.

Listen in to get ideas for how you can improve your helpline’s effectiveness.

By Adam Turteltaub

Each year countries lose billions to corruption, fraud and other compliance failures.

When it comes to stemming this problem, helplines are crucial.  In fact, a study by the Association of Certified Fraud Examiners found that 50% of corruption cases were found through tips from employees.

The challenge for helplines is that there is often an assumption that the calls will come in through a landline.  For much of the world, though, that’s not the case.  Employees are more likely to have mobiles, and that toll-free number isn’t toll-free.  Worse, problems often arise in developing countries where English or other European languages may not be widely spoken.  If your helpline provider doesn’t have a native speaker on premises, it can lead to long delays and awkward three-way calls with a translator.

Paula Davis of Waypoint GRC encourages compliance officers to begin rethinking how they put their helplines to use and explore alternatives such as apps.  She also advises “mystery shopping” the line:  making test calls in multiple languages to see how well the helpline provider handles them.  Also, she suggests asking the provider for abandoned call rates, to see if people are staying on the line.

Listen in to get ideas for how you can improve your helpline’s effectiveness.

By Adam Turteltaub

The 2019 European Compliance and Ethics Institute began with a riveting address by Drago Kos, Chair of the OECD Working Group on Bribery. The OECD has played an enormous role in the anti-corruption efforts, setting standards that countries commit to, and holding them to public account if they fail to meet their obligations.

After his talk, he took the time to record a podcast in which he shared some of the key points covered in his longer keynote address.  These include:

* Only half of the OECD members have been active in anti-corruption enforcement, but there has been an increase

* Rising nationalism has come with increased indifference to international standards and efforts, including the fight against corruption globally and domestically

* High trust, he believes, leads to less corruption: to fight corruption you must first build trust

* The OECD is working on revisions to its 2009 recommendations for combatting bribery, and this will include a public comment opportunity

* The latest series of country reports shows some progress but also serious deficiencies

Listen in for his insights, concerns, and warnings.