Michael Volkov and Donna Boehme offer a revolutionary look at how Corporate Compliance Officers can approach their work in “Fielding a ‘Moneyball’ Compliance Program,” in The Compliance Strategist at www.corpcounsel.com. This article breaks down convention and reexamines old traditions to provide readers with a refreshingly relevant view of corporate compliance programs, including a section titled “Tone Down the Happy Talk.” The authors offer modern day insight into the complex tasks CCOs face:
“For an achievable 2014 goal, we suggest that chief compliance officers resolve to think much more strategically about how they allocate their resources, and rethink their ‘ask’ of the organization. Existing program elements should be reviewed for opportunities to streamline efforts, leverage resources and eliminate non-value-added processes.
Going forward, every new task, initiative or investment should be analyzed in the planning stages to confirm if and how it adds value to the overall long-term and short-term compliance workplan and should be discarded if it doesn’t. (Nothing undermines the credibility of the compliance program faster than complaints like: ‘We just went through this same exercise three months ago for internal audit.’)”
The authors offer several areas where CCOs can leverage this advice, including: Stop Collecting Data for Data’s Sake, Rethink the Ubiquitous “People Survey,” Make Sure Training Has a Purpose, Maximize Business Partner Due Diligence, and Tone Down the “Happy Talk.” Read the entire article here.