IT Business Edge offers 3 questions and answers on challenges involved in compliance training. The answer to question 3 on the interplay between leadership and corporate codes of conduct is instructive:
A good compliance initiative has the leaders managing the process and not the people. If the process is properly managed, the people will actually follow. One may argue that not all will follow, which is true. The reason you need the process is to handle discrepancies, so it’s always about the process. This is communicated through the corporate code of conduct. It sets up consistent expectations so that you don’t have to manage every fine detail of employee behavior.
Corpedia notes 8 best practices in corporate compliance and training. Practice #2 bears upon the leadership issue: setting the proper tone at the top. Former leaders of Tyco, WorldCom and Enron under indictment were probably not seen by key employees as having the proper commitment and respect for compliance. This may even be true for those Tyco employees who weren’t invited to the party.
In my experience practice #5–respecting employees’ time–is also important. One way of doing this is making compliance part of the daily routine and not just some once-a-year training to be endured until the obligatory sign-in sheet passes by.
Update (20 Sept 05): Kozlowski and Swartz are sentenced to up to 25 years in prison. Bad news: it’s likely Sing Sing or Attica (not Rikers Island, per a loyal reader), state penitentiaries, not a federal, Martha-type facility. Good news: the state allows parole after 8+ years, likely less than current federal sentencing guidelines would require.