Building Blocks of an Effective Compliance Program

You’ve written a compliance policy, prepared training sessions and done everything you can to set up your company’s compliance program. What happens when the program gets legs and takes off?

Posted by Joe Gerard in Ethics & Compliance on January 4th, 2011

You’ve written a compliance policy, prepared training sessions and done everything you can to set up your company’s compliance program. What happens when the program gets legs and takes off? Will it land on its feet or stumble and fall? In many organizations, there are barriers to overcome – or, red flags perhaps, that influence the success of a compliance program. I had the opportunity to interview Anthony Boswell, an experienced educator, lawyer and compliance program builder. Anthony and I talked about some of these “red flags” based on his experience in the compliance field.

Red Flags

Anthony stresses the importance that the presence of a single red flag doesn’t mean your compliance program is doomed. However, if present as a collective, these signs signify that it will be challenging for the compliance program to be effective. Some of the red flags include:

  • Budget Constraints- Telling the compliance department they can’t have money for audits and other activities makes it challenging for them to get the job done. Audits and reviews provide compliance with the information they need to address risks and other issues that might hurt the company if they aren’t corrected.
  • Lack of Leadership Support- Culture is defined by the tone at the top. If there’s no support from the top, a compliance program will, without a doubt, fail. I discuss the importance of leadership below.

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  • Employees/ Managers Going Above You- When employees or managers go to compliance for an answer, but don’t like the answer they receive, in some companies, they will go above compliance to get the answer they want to hear. This snubs the compliance program and communicates that compliance doesn’t matter.
  • Organizational Culture- Cultures that aren’t open to discussion or disagreement make it difficult for a compliance program to work. When the compliance team isn’t part of leadership, invited to meetings or given a voice in the company, it makes it hard for compliance programs to be successful.
  • Compliance as a Cost- Leadership needs to switch their outlook from the present to the future to see the value or the return on investment of a compliance program. In the short term, compliance is a cost, but in the long term, compliance will save your company a lot of money in legal fees and fines.
  • Threats- Watch for comments like “just go along with us on this one” or “this is a decision we already made”. Comments like this show a disregard for compliance.

Culture and Leadership

Culture and leadership are the two keys to compliance program success. The involvement of top level management in the compliance program and the inclusion of compliance in everyday life within the organization are critical. Anthony told me that one of the most important things a CEO can do is ask “did you run that by compliance?” When the CEO shows a concern for compliance, employees start to get the message that it should matter to them too.


The right leader, the right people and support. These three things are the foundation for a well balanced and adoptable compliance program. As a leader, stand your ground, raise issues and capture resources to allow the compliance department to do their job. Some of the ways management can ensure success:

  • Intrinsic support (asking the tough questions)
  • Providing the compliance departments with time and access to employees for training and any other additional purposes.
  • Give the compliance department sufficient resources. This goes along with the point above about viewing compliance as a cost and budget constraints. If compliance needs additional people to function, funds for a program or audit, do your best to provide them with such resources.

Employers need to be aware of what they are getting into and not back down when the times get tough. If you believe in compliance, fight for it.

Once again I’d like to thank Anthony for taking the time to speak with me about such an important topic. The advice he has to offer is incredibly valuable! If you wish to contact Anthony, you can do so by email at: anthonyoboswell at aol dot com

Joe Gerard
Joe Gerard

CEO, i-Sight

Spend my days showing off the i-Sight investigative case management software and finding ways to help clients improve their investigations. Usually working with corporate security, HR & employee relations, compliance and legal teams.

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