People-Power Your Compliance Program

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Gloria Thompson
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1 People-Power Your Compliance Program Mary-James (Jami) Young Senior Counsel, Compliance and Regulatory Vectren Corporation October Overview Why People-Powered Compliance? Culture of Compliance Tone at the Top Five Pillars of People-Powered Compliance Empowerment Responsibility Resilience Integrity Measures (not metrics, measures) Criteria High Impact/Low Cost Program Enhancements Accessible, Workable Changes and Tweaks Tangible Results/Positive Outcomes Applications Beyond compliance enhance the rest of the business, and the rest of life Easily communicated, transformative changes Ripple effects of positive changes 1

2 People-Power What is people power? Why does it matter? How do we harness/direct it? How does it interface with gee whiz GRC software solutions? Can it be taught/learned? How does it start? Five Pillars Why Five Pillars? Foundational to our Compliance Efforts We grow our people We recruit from within our Company We receive inquiries from employees who want to join compliance (!!!!) We studied Human Factors, Human Performance and Humans as Heroes. Empowerment Humans as heroes Mindful, present, engaged and thinking through every function, every day Spotting issues and potential problems and correcting those before they manifest Proactive, not reactive Aware of and educated in the core mission, and EMPOWERED TO MAKE GOOD THINGS HAPPEN Empowered to stop bad things from happening 2

3 Responsibility Personal Responsibility No one walks past a problem Everyone works together to solve a problem Everyone proactive in anticipating potential problems and taking steps to correct those quickly (see Empowerment) Everyone owns the processes and the outcomes Everyone invests in the success of each of us When one of succeeds, we all succeed.. Resilience Personal Resilience leads to Group Resilience What is resilience? In life In compliance programs Why does resilience matter? Where does it come from grown or learned? How do we foster resilience among our compliance professionals? Resilience is picking up the pieces, and putting it back together BETTER than it was Integrity Doing the right thing, every time, even when no one else is watching what we do Knowing the right thing to do Understanding how to model and lead others toward the right thing to do Recognizing that the journey matters as much as the destination Building good choices into good actions and good results for a great compliance program 3

4 Measures, Not Just Metrics Query how do we measure a culture of compliance, anyway? Demonstrably robust Culture of Compliance: Federal Sentencing Guidelines Federal (and some state) Regulatory Enforcement Matrices Tone at the Top communicated expectation that we do the right things No consensus on the right measure(s) Strong consensus that measures not chill or inhibit the culture of compliance Measures, continued Two Purposes for our Measures: Internal diagnostic tool to identify blind spots, compliance risks, and areas for improvement Means for providing targeted, anonymous feedback and ideas for improvement Methodology: Seven open-ended questions posed in a facilitated interview setting Responses compiled and assessed and acted upon Bonus Features: Managing the 3 Cs: Change, Conflicts and Compliance Change Management: three elements, always Logos, Pathos, Ethos or Rider, Elephant, Path Conflict Management: five steps to success Hold your fire, disarm your adversary, change the game, find the yeses, tap your inner third force Compliance Management: GRC software programs will come and go, and people are a constant element of any compliance program 4

5 Three Things to Remember, Always: In Compliance (and in life). Context is Key See the big picture, always Understand the pull and tug of external forces Everyone has a boss Know your constituencies Recognize and diffuse those battles by proxy Everyone Brings their Own Baggage Acknowledge your baggage Anticipate the baggage of others Meet the unspoken needs; success from both perspectives Build the Relationships as You Go Choose your battles Look for Face-saving opportunities (theirs and yours) Courtesy is cheap and effective and the right thing to do Conclusions Recognize and understand the key role that people play in any compliance program Harness and direct people towards positive contributions to program and to the larger culture of compliance Acknowledge successes and leverage those teachable moments to really teach your people (and watch and cheer while they teach others, and the cycle continues ) Thank you. Questions? Comments? 5

People-Power Your Compliance Program

People-Power Your Compliance Program Mary-James (Jami) Young Senior Counsel, Compliance and Regulatory Vectren Corporation October 2013 mjyoung@vectren.com; maryjamesyoung@gmail.com Overview Why People-Powered