Compliance Perspectives

By Adam Turteltaub

Roz Bliss is the Manager, Global Integrity at Northrop Grumman.  One of the responsibilities of that role is putting together a meeting for the global ethics team.  It’s not an easy task, with such a large and spread out team.

Over the years she’s learned to manage not just the logistics but the substance of the meeting as well.  By chance Northrop Grumman was having a team meeting at the same time and hotel as the 2018 SCCE Basic Compliance and Ethics Academy in Amsterdam.  While we were both there, she sat down to share her experience on the ingredients of a successful team meeting.

Listen in as she shares her tips, including:

* Know your audience, including how on-time it tends to be (it varies by country)

* State your purpose and manage expectations up front

* Be considerate of the time of participants

* Involve the right people in planning, including some who may oppose what you plan on doing

* Plan on asking questions: don’t make the whole program a speech

* When following up, include people who were unable to participate

 

By Adam Turteltaub

Most companies are well-versed in handling discipline in the context of a compliance failure.  But when it comes to the other side of the coin – providing incentives for and reward good behavior – many struggle.  That’s a problem given that providing incentives is one of the elements of an effective compliance program.

Greg Triguba, one of the faculty members at the SCCE Basic Compliance and Ethics Academies, argues that incentives may be more important than discipline.  People want to see what the company cares about in a positive way, and simply having incentives for good behavior, like having them for sales, says that this is what the company cares about.

In this podcast, recorded at the SCCE Academy in Amsterdam, Greg addresses:

* The importance of the compliance and ethics team having a seat at the table when the company is formulating its incentives program

* The use of past failures to make the case for including incentives

* Using the code of conduct as a basis for setting standards

* Thinking beyond cash incentives

Listen in.  You’ll find his thoughts on incentives rewarding.

By Adam Turteltaub

Most companies are well-versed in handling discipline in the context of a compliance failure.  But when it comes to the other side of the coin – providing incentives for and reward good behavior – many struggle.  That’s a problem given that providing incentives is one of the elements of an effective compliance program.

Greg Triguba, one of the faculty members at the SCCE Basic Compliance and Ethics Academies, argues that incentives may be more important than discipline.  People want to see what the company cares about in a positive way, and simply having incentives for good behavior, like having them for sales, says that this is what the company cares about.

In this podcast, recorded at the SCCE Academy in Amsterdam, Greg addresses:

* The importance of the compliance and ethics team having a seat at the table when the company is formulating its incentives program

* The use of past failures to make the case for including incentives

* Using the code of conduct as a basis for setting standards

* Thinking beyond cash incentives

Listen in.  You’ll find his thoughts on incentives rewarding.

By Adam Turteltaub
[email protected] the 2018 Compliance Institute in Las Vegas, Jennifer Michael was good enough to sit down for a podcast.  Jennifer is the Chief, Industry Guidance Branch, Office of Counsel to the Inspector General at the Department of Health and Human Services.

In this brief but fact-filled session she provides an overview of HHS Secretary Alex Azar’s key priorities:  combatting the opioid crisis, decreasing the cost of prescription drugs and increasing the accessibility and affordability of healthcare.  She also addresses:

* Value-based payment arrangements and the push for value over volume* Having a strong process for identifying risk areas* Recent key advisory opinions 1701, 1703 and the rescission of advisory opinion 0604Listen in to hear her perspective.

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By Adam Turteltaub

At the 2018 Compliance Institute in Las Vegas, Jennifer Michael was good enough to sit down for a podcast.  Jennifer is the Chief, Industry Guidance Branch, Office of Counsel to the Inspector General at the Department of Health and Human Services.

In this brief but fact-filled session she provides an overview of HHS Secretary Alex Azar’s key priorities:  combatting the opioid crisis, decreasing the cost of prescription drugs and increasing the accessibility and affordability of healthcare.  She also addresses:

* Value-based payment arrangements and the push for value over volume

* Having a strong process for identifying risk areas

* Recent key advisory opinions 1701, 1703 and the rescission of advisory opinion 0604

Listen in to hear her perspective.

By Adam Turteltaub

Not getting indicted is a very low bar to set and one that few, if any organizations, aspire to.  The vast majority want a company that operates lawfully and with an ethical culture.  But how do you get there?

Sally March addresses the topic both in this podcast and when she teaches at the International SCCE Basic Compliance and Ethics Academies.  While at the Amsterdam Academy she took some time away to share her thoughts on organizational ethics.

Join us as she discusses:

* The growing expectation that the board should be responsible for creating an ethical culture, both because it is the right thing to do and because it leads to long-term business success

* The importance of purpose and values for aligning workforces, no matter how dispersed they may be

* The value of honest conversations about tough situations

* Giving employees the opportunity to practice handling real-life scenarios, especially those that actually happened inside the organization

* Soliciting feedback from employees as well as customers and suppliers

* Making the business case internally for ethics

By Adam Turteltaub

Not getting indicted is a very low bar to set and one that few, if any organizations, aspire to.  The vast majority want a company that operates lawfully and with an ethical culture.  But how do you get there?

Sally March addresses the topic both in this podcast and when she teaches at the International SCCE Basic Compliance and Ethics Academies.  While at the Amsterdam Academy she took some time away to share her thoughts on organizational ethics.

Join us as she discusses:

* The growing expectation that the board should be responsible for creating an ethical culture, both because it is the right thing to do and because it leads to long-term business success

* The importance of purpose and values for aligning workforces, no matter how dispersed they may be

* The value of honest conversations about tough situations

* Giving employees the opportunity to practice handling real-life scenarios, especially those that actually happened inside the organization

* Soliciting feedback from employees as well as customers and suppliers

* Making the business case internally for ethics

By Adam Turteltaub

Shawn DeGroot is not a big fan of waiting for the regulators to knock.  Instead, she advises compliance officers to reach out to regulators proactively, even before anything goes wrong.  By establishing a relationship with the regulator, she explains, you can build trust and have a resource when you need one.

In this podcast she explains:

* The benefits of having a relationship with the regulators

* The need to remember that regulators are human and have a job to do

* The importance of honesty and transparency

* How you communicate can be especially important

* What to do after a conversation that went wrong

Listen in before you reach out to your regulator, whether for the first time or the umpteenth time.

By Adam Turteltaub

Shawn DeGroot is not a big fan of waiting for the regulators to knock.  Instead, she advises compliance officers to reach out to regulators proactively, even before anything goes wrong.  By establishing a relationship with the regulator, she explains, you can build trust and have a resource when you need one.

In this podcast she explains:

* The benefits of having a relationship with the regulators

* The need to remember that regulators are human and have a job to do

* The importance of honesty and transparency

* How you communicate can be especially important

* What to do after a conversation that went wrong

Listen in before you reach out to your regulator, whether for the first time or the umpteenth time.

By Adam Turteltaub

Most companies don’t start out with a full-time compliance team.  Heck, most probably don’t even start with a part-time team.  But as an organization grows, eventually it is time to take the plunge.

Tony Joy from Empower Audit Training & Consulting has worked with several companies who have made the transition from a parceled out compliance function to a dedicated one.  Not surprisingly, over the years he has found that sooner is better than later when it comes to starting a compliance program.

That doesn’t mean, however, that you need to dive completely in.  He recommends a phased approach beginning with leadership buy-in.  Then it’s time to get some help, whether by forming an internal team, engaging outside consultants or turning to resources of outside groups like the SCCE.

Listen in to this podcast as he provides some more helpful insights into the formation of a compliance program, as well as the missteps that can leave you farther behind than if you hadn’t started at all.