I attended the SCCE’s recent Utilities and Energy Compliance conference in Houston. It is always a great meeting with terrific speakers and content.

I was fortunate to attend a session, Taking the Pulse of Corporate Culture, presented by Amy Lilly from CenterPoint Energy and Steve Helm from NAVEX Global. A copy of the slides is here.

Their presentation focused on how to build tools to measure your compliance culture; how to conduct measurements; and how to report in the company on the results.

As explained by Amy (I will refer to Amy but please note that this was a joint presentation and it gets a little clumsy repeating “Amy and Steve”), one of the key inquiries is how to define “effectiveness” in the context of your unique risk profile. There are many goals all companies share but some may be unique or more important depending on your over all risk profile. Based on this risk profile and the focus of your mitigation strategies, the key is to identify a measurable goal, seek to accomplish it, and then measure whether you have been successful.

CenterPoint defines its measureable success by its tone at the top; mix of awareness communications, roundtables, surveys, telephone based reporting and online training; ethics and compliance risks incorporated into enterprise risk management; exposure to the board of directors for reporting; metrics to validate need for change in specific areas; and partnering across the organization.

For Tone at the Top, CenterPoint’s CEO proactively addressed the VW scandal as a teaching moment to promote integrity in the workplace, and CenterPoint followed up by issuing a Manager’s Toolkit to ask staff the question – “What does integrity mean to you?”

One of the more interesting aspects of CenterPoint’s program was its Roundtable Program, which is used to increase ethics and compliance visibility and availability, to assess the health of the organizational culture, and to spot trends in the company.

Amy explained how she and her staff identify participants and pick locations to conduct the roundtables, create agendas, and conduct surveys after each session. Members are randomly selected from the population within a specific area or segment.

The roundtables focus on a number of important issues:

• Have the participants read the company’s code of conduct?
• What are the company’s values?
• Provide examples of how those values are applied on the job?

The post roundtable surveys are important measures of corporate culture. Amy cited a specific example of the question whether a person would report a friend if the person’s friend behaved unethically?

Interestingly, approximately 70 percent of CenterPoint’s respondents to this question answered in the affirmative.

Another key measure in CenterPoint’s compliance program is the extent to which they coordinate with other important functions such as Human Resources, Audit, Information Technology and Finance. Hui Chen, DOJ’s Compliance Counsel, cited this same factor as a key issue she examines to determine whether a company’s compliance program is operational or a paper program. We all know that compliance requires effective internal relationships and collaboration — no compliance program has enough resources or internal touch points to ensure effective operation; in the end a compliance program must have internal partners and strong relationships with key functions.

CenterPoint’s Roundtable Program is one of many innovative approaches to measuring corporate compliance programs and culture in particular. While the sampling techniques may not be statistically pure, the data itself can be relevant to spotting trends and measuring overall awareness and influence.