It’s very easy in a big organisation to write a policy saying the business complies with the relevant regulatory regime. It is duly published and maybe some interactive training takes place. Job done.
But is that real compliance? Does it change behaviours and embed compliance in the culture of the company? Does, as somebody said this week in one of the sessions I attended, the issue “come off the page” and be real.
It will probably only do this because of pressure of some sort or other. I used to work in the oil industry. On 28th August 1928 at Achnacarry Castle in Scotland three dominant oil companies entered into a price fixing agreement. Many years later an American antitrust action was settled against the major oil companies on the basis of a Consent Decree.
Violation meant huge fines and for the oil industry this was very real. If as a salesman you received a call from another company and price was even mentioned, unless you stopped the call immediately and went to tell your lawyer – you were sacked. Fear led compliance maybe but compliance all the same.
It’s really important nowadays to actively and effectively comply not only because of legal sanctions but peer pressure and the impact on reputation with bad news in this respect spreading around the Internet like wild fire when there is for example a data privacy leak.
“Ethics in business is extremely important; your reputation is all you have in life.“ - Sir Freddie Laker - one of the first airline owners to adopt the "no-frills" airline business model that has since proven to be very successful worldwide with companies such as Southwest Airlines, Ryanair, and easyJet.
Notional compliance won’t work. At some stage, it will find you out. It has to be real, off the written page, and instilled in the very fabric of the business.
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