I am attending the ACI Foreign Corrupt Practices Act (FCPA) Boot Camp in Houston. It is one of the best FCPA events held in Houston annually. It brings together some of the top local compliance talent, together with top national practitioners. One of the presentations was on how to tell your compliance story. It presented several interesting aspects of how to not only communicate your internal compliance story but how to also market compliance within your organization. Céline Gearson, Chief Ethics and Compliance Officer at Cameron International, had an interesting perspective on how she internally markets her compliance function. She termed these as “The Five Golden Rules of What Works”.
1. Socialize, Socialize, Socialize
Gearson believes that it is critical for the compliance practitioner to foster strategic relationships with key stakeholders within your company so that you can explain the compliance function on a one-to-one basis to get their buy-in. The importance here is to build those relationships prior to any compliance program implementation. She specifically mentioned the IT and Marketing departments. Another person I would add is the Corporate Secretary, the reason for this is that the Corporate Secretary has several constituencies within the company that he or she may work with and for. This can provide an opportunity to view a company’s ethics and compliance program and to help shape and direct it. The Corporate Secretary, head of IT or Marketing may be excellent resources to the Chief Compliance Officer (CCO), which may be under-utilized. It might be worth a cup of coffee or short meeting to see what they might think about your ethics and compliance program or how they might be able to assist you in your efforts.
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