Trojan CorporateTrojan Corporate

By Narelle Davidson

Is compliance a priority for you now?

Compliance is a cost of doing business, but is compliance a priority for you now?

Is compliance a priority for you now?  Compliance certainly has the capacity to impact the bottom line.  A business with poor compliance may not have the same capacity for growth as one with solid compliance practices. For a number of reasons, compliance may not be a priority for some businesses.  The reality is that compliance may not be allocated the same priority as other business functions, like marketing, promotions or sales.  For some, it’s boring, mundane and is someone else’s responsibility.   Perhaps there are other more important things to worry about? Compliance is probably under control….or is it?  Everything will be ok if we are doing the right thing…won’t it?

Compliance is a part of doing business and needs to be resourced appropriately.  For many, compliance has become a burden.  Although compliance may not be the most exciting area of the business it can become an even bigger burden if not given the attention it deserves. Perhaps there are other areas of the business that require attention.  However, while attention is focused elsewhere exposure could be lurking.  If compliance is not a priority now, it could become an unwanted problem in the future.

Last week I wrote about consistency over time = results.  In thinking about the goal/s we want to achieve, a culture of compliance is where the real value is.

The key is attempting to ensure future compliance.  Ted Fitzgerald

How do we ensure future compliance?

Developing a culture of compliance in the business is sure to help ensure compliance in the future.  Creating a culture of compliance is possible and essential to adding business value.

Here are some questions to ask:

  • Do we understand the compliance risk in our business?
  • Is compliance adequately resourced?
  • Do we have the necessary policy and procedures? Are the policy and procedures clear? Does the team know and understand what is required of them?
  • Has there been communication to the team about compliance expectations? How did the communication take place?  Was it effective? How do we know it was effective?
  • Have we trained our team appropriately?  Did we assess the learning? Do we have appropriate training records?
  • How do we know that the right thing is being done? Is there evidence to support that the right thing is being done?
  • What needs to happen when something is not right or a breach occurs? What do we do when matters of compliance are brought to our attention? Who will be responsible for acting on such matters? How do we know such matters have been acted upon? How do we know if the action is effective?

Take the time to ask the above questions.  Think about the answers.

How do you feel about ensuring future compliance?  Has compliance just become a priority for you?

 

 

By Narelle Davidson

Compliance Culture, group cohesion, continual improvement

I recently spoke to a group of venue operators about compliance culture, group cohesion and continual improvement and discussed the benefits of creating a culture of compliance within their businesses. The benefits of creating positive culture include; improved teamwork and greater commitment, positive team relationships and greater profits.

One of the many challenges faced by club managers is creating a great team. Once you have a great team, how do you keep that team together and working towards the same goals?

The tone set from the top will determine how the team align their compliance values. Knowing that you have set the right tone is imperative. The top down message must be united, clear and uncompromising.

‘Organizational culture plays a role in shaping employee behaviour and encouraging compliance.’ Sustaining an Organizational Culture of Compliance – Whitepaper SAI GLOBAL

Behaviour is visible. A persons attitude is less visible, but directly affects people’s behaviour, be it positive or negative. To find out the attitude of our business we really need to get to know our people.

There are theories that exist about group attraction and that groups become stronger when they have mutual positive feelings to each other. Having our basic needs met allows us to move on to greater levels of growth.   As employers we can also impact on higher needs like belonginess, esteem and personal potential.

When we work together as a team we feel better about ourselves, this can have extremely positive effect on individuals and on our business.

The importance of having goals is critical to keeping teams together. Not only that, it is critical to employee satisfaction. Satisfied employees are more likely to be engaged. They more likely they are to care about:

  • their job,
  • their workmates,
  • their employer,
  • and your customers.

The personalities of our leaders is critical to developing strong cohesive groups. People are much more likely to stay together as a group when group cohesion is strong, they are also much more likely to participate in and add value the group.

As individuals we need a purpose. In groups we need purpose and leadership. Tone from the top is critical and so our leaders must be strong and competent. When we have this we can achieve a culture of compliance and even better organisational culture and people culture.

“There is only one valid definition of business purpose: to create a customer”. Peter F. Drucker

The success of our business is subject to the engagement of our employees and satisfaction of our customers.

 

By Narelle Davidson

Compliance training – box ticking or behaviour change?

Should compliance training be a box ticking exercise, or can it support a healthy compliance culture, by engaging employees and changing behaviour?

Compliance training is primarily to educate employees on the regulatory requirements of their job.  Compliance training also includes training in venue policy and procedure. Much compliance training is aimed to tick a box and prove to the regulator that the training has been provided and completed.

There is no denying compliance training is a difficult sell to employers and employees. The costs can be expensive, content is often dry, specific and low on creativity.

Should compliance training be both – box ticking and behaviour changing?

Yes, compliance training needs to tick the box, but it can achieve so much more when it is aligned to strategic business objectives.  This is difficult when training (like Responsible Service of Alcohol and Responsible Service of Gaming) is mandatory and must be delivered by an approved registered training organisation or trainer; however, choosing a training company that aligns to your business values is one way to encourage behaviour change.

Training such as; privacy, anti-bullying, harassment and discrimination, AML/CTF, and tobacco is another opportunity to promote your venues policy, values, attitudes and beliefs and work towards behaviour change.

The training program of the compliance framework is an important element to creating a healthy compliance culture and encouraging behaviour change. Take the time to consider these points:

  1. Training must add value. Keep the participants engaged. It is important to create current content that is relevant to the learner. People don’t want to sit through a training session and not learn anything. It is important to back up training with in-house or refresher courses or procedure training. Understand who the participants are and ensure that the language and content meets their needs. Use case studies, scenarios and practical exercises that reinforce the learning.
  2. Consider the frequency of delivery – too much is overload, too little is risky.  Allocate a budget, resources and time.   Take the opportunity to plan the program rather than provide ad hoc training that adds little to no value.
  3. If using external providers choose one who has a solid reputation for delivering compliance training that is fun, engaging, current, professional, practical and informed. Well researched content combined with solid practical experience can differentiate boring compliance training and trainers. Same said for internally delivered training.
  4. Consider how technology can make compliance training easier. Visuals are great. Technology can be utilised for delivery, training registers, reminders and, or record keeping.
  5. Above all the training program must be endorsed from the top down. Team leaders must not only participate in compliance training but understand it.       Training must be reinforced away from the training room and for this to be achieved management must understand how to implement and integrate what they have learnt into the business. Managers must lead by example and be capable to influence behaviour change.

“Education is not the learning of facts, but the training of the mind to think.”  Albert Einstein.

If you have got a little bit of time and want to read more, this article discusses compliance training in more detail http://charles-jennings.blogspot.com.au/2012/08/compliance-training-does-it-really-work.html

By Narelle Davidson

Setting the tone from the top

Setting the tone from the top may well be the lone critical factor to a successful compliance program

Senior management and boards need to endorse compliance. A solid compliance program can help you achieve business strategy, values and objectives; provided the program it is aligned to them. Without the commitment from “the top”, achieving a compliance culture will be a struggle. It will be difficult to implement any policy and it will be a bigger challenge to create that “walk it like you talk it” culture. #3 of my top compliance tips for 2015.

The importance of the business objectives and values cannot be denied

The values that have been determined by those “at the top” must be communicated further than the Board room.  They must be shared with everyone the business engages with. Teams align with strong vision and values. When the team does not have a purpose the message is unclear, the purpose unsure, the work hard and the result disappointing.

Just as important to the strategy, values and objectives is the tone from the top

“Attitude is a little thing that makes a big difference.” Winston S. Churchill.

Tone is important; knowing that it is the right tone is imperative. The compliance tone from the top will determine the how the team align their compliance values. The top down message must be united, clear and uncompromising. Take the time to assess the tone. Is everyone “at the top” walking the talk?

Those with strong vision and values will be in a better position to ensure that compliance culture comes naturally rather than forced. The vision must be achievable and everyone committed to it. Provide the team with a direction that they can and will want to commit too. Provide them with a vision. This will be the compliance culture – the attitude, belief, value and custom of your Club driven by the tone from the top.

“The meaning of things lies not in the things themselves but in our attitude towards them.” Antoine de Exupery

By Narelle Davidson

Raising compliance from the bottom of the pile

It is generally quite obvious when a venue has a good grasp on their compliance obligations from the moment you park in the carpark, walk in the front door and are greeted by the team. Strong values create strong standards.  One of the most memorable experiences I have is walking into a venue and smelling rancid deep fryer fat, pushing past empty kegs to make my way to the office area in which chaos can only explain first impressions. My gut told me if it smelt and looked bad it was probably going to be bad. Needless to say compliance was definitely on the bottom of the pile.

In over 9, or so years of reviewing compliance for hospitality venues, I’ve seen instances of complete disregard for company policy and procedure, I’ve listened to many raise cause for the circumvention of compliance and wondered what would happen if the same energy was spent in putting to a plan for complying.  I have also been witness to watching compliance rise from the bottom of to do piles and sit comfortably within club culture. How is it done?

Here are my top 10 suggestions to get you back on track to creating compliance value, attitude, belief and custom.

  1. Set the tone from the top. Communicate the mission, values, and vision for your club.
  2. Dedicate resources – time, financial, people. Assign responsibility – it’s a team effort.
  3. Screen employees. Don’t let one bad egg spoil the basket.
  4. Accountability is great, but make sure it’s achievable. Don’t ask people to do things that can’t be achieved. Break it down into digestible and realistic chunks.
  5. Take time to understand compliance obligations and risks. Undertake a risk assessment or independent review. A fresh set of eyes will identify things that have become invisible on a day to day basis.
  6. Follow up – set reminders for important dates and time frames.
  7. Engage the team to see compliance as an asset not an interruption. Encourage team members to speak up when something is not as it should be. Bottom up approach is critical.
  8. Train team members in company policy and procedure. Try to think of ways that this can be done that are a little out of the box.
  9. Test compliance. Reward the team for compliance met.
  10. Report to the board on the status of compliance within the business.

Achieving compliance culture is not only possible, it is essential to adding business value.

Is compliance a priority for you now?