I’ve never been one for New Year’s resolutions myself. I still think in terms of school years and tend to do my own reassessment in September. But regardless of when your “new” year begins, it is always good to take a look back at the year gone by and forward to the year ahead.
I worked in Russia in a former life, so I sometimes see my work in terms of the old Soviet 5-year plan. We need to recognize that building and maintaining an effective ethics and compliance program is not a short-term proposition. It is good to have a 3-5 year strategy for the program and take it out every so often to see if we are where we need to be for long-term success.
In addition to the long-term strategy, it is good to have an annual plan. What goals did you set for yourself and for the program last year? Did you achieve what you had expected to achieve? Did events intervene that distracted or derailed you? Like Brexit? A lot of us are still trying to figure that one out.
Were the events matters of corporate strategy, such as a major acquisition or restructuring? If so, did you have a seat at the table and were you able to provide meaningful input at the right time?
Were you able to adapt your compliance plan to take this into consideration? If the answer to either of the last two questions was “no,” what could have been done differently to achieve a better result?
Was there a compliance breach or investigation last year that disrupted the business? If so, what lessons have been learned from it, and how are those lessons going to be used to improve the ethics and compliance program?
And then we get to look to the year ahead. When I am setting my goals within an organization, I like to switch off the computer, turn off the phone, and just have a good think.
What could I do that would have the largest impact on the company?
The answer is never in my inbox. We should recognize that we are the experts on proactive programs to prevent misconduct. The stuff in the inbox is usually reactive or tactical.
Often what we need to do more of is building relationships with other functions, seeing what they see, learning, listening, and connecting dots. Make sure you have that in your plan, too.
Have an ethics and compliance question for Sally March? Email Sally at email@example.com!
Sally is an international commercial lawyer and certified compliance and ethics professional with extensive experience in Russia and the CIS, as well as the US and Europe. Her interests focus on cultural issues in organizational change and using corporate culture to protect reputation and enhance brand value. Sally March directly contributed to our Ethics and Code of Conduct course.