As we prepare to roll out our 2011 Global Ethics & Compliance Benchmarking survey, we are reminded how imperative it is to differentiate between a “common practice” and a “best practice”. Even if 80% of all organizations take a similar approach or leverage similar resources in a similar way, this does not indicate whether this practice is inherently “better” (i.e., an improvement on previous practices) or even “best” (i.e., the most effective and beneficial of practices, given current options) for an organization.
Common practices may offer great general guidelines, and might even be a significant improvement in how things are done in many situations (especially if nothing is currently being done in this area), but “best practices” is, in some ways, a misnomer. There is no single standard for “best” that can be applied to every organization. An effective ethics and compliance program will determine its own “best” practices, leveraging current best practices in an organization’s industry (i.e., the differences between successful ethics programs at oil and mining companies versus telecom or retail giants), while also taking into consideration trends in the ethics and compliance profession (e.g., ideas from thought leaders in the field), the organization’s own best practices (what worked better in 2007 than in 2010), and of course external guidelines such as the Federal Sentencing Guidelines.
For example, having a local network of compliance professionals is considered by most to be a best practice. Some organizations may find that their best results come from individuals who are hired into the local ethics and compliance role as a dedicated resource while others may find that local employees who are already an integral and trusted team member at the organization, and who have sufficient time to commit to the ethics and compliance program, provide the best results. In some cases, the best internal resources may come
from the local HR team (and are skilled at counseling employees, providing training and coaching, etc.), whereas others may come from line management (those who interface with line employees daily, are a trusted source of personal leadership, etc.).
Or for example, your organization may determine that the online community and e-mail newsletters for local compliance teams, while less expensive than multi-country conference or video calls, have been markedly less effective in building understanding of the program’s goal and initiatives, not to mention the sense of team spirit that the monthly conference calls provided in previous years. In this case, the organizational best practice might be to revert to a face-to-face or “voice-to-voice” format for maintaining the network, regardless of how successful online communities may be working for other organizations.
“Best practices” change with time. They come about as new and different resources become available (i.e., consider the omnipresence of e-learning as a training tool in modern ethics and compliance programs), as experience provides us with better hindsight (i.e., consider the way you used to structure your employee training as well as the examples you used), and sometimes merely because we stumble upon a good idea from someone who has been reflecting on what will make the ethics and compliance profession just a little more
If you are involved in your organization’s global ethics and compliance program and are interested in participating in our survey, please contact us. To see the results of previous benchmarking surveys, visit: www.languageandculture.com/benchmarking-survey