Chief compliance officers know the importance of trust, not just as a foundation of a global company’s compliance program, but in the context of knowing what company employees are doing out in the field. CCOs will always say they have a “feel” for what is going on at the company but when they are reminded of how little visibility they have into company operations around the globe, they will quickly acknowledge they really do not know what is occurring out in the field.

Most CCOs love compliance data. It gives them a window into whether or not managers and employees are complying with controls.

Basic questions become basic reinforcements:

• Are employees completing code of conduct trainings?
• Are employees executing annual certifications?
• Are employees completing required due diligence processes before onboarding a new third party?
• What do employees think about company leadership?
• Have employees witnessed employee misconduct, and if so, did they report it?

These are examples of the types of basic questions that are important to CCOs.

In reality, there are many valuable sources of compliance data that is relevant to a CCO from which the CCO can glean a picture of a company’s culture and operations.

A Speak Up culture, if robust, gives companies an opportunity to collect and analyze continuous data on a compliance program.   In its 2017 Ethics and Compliance Hotline and Incident Management Report (here), NAVEX cited the fact that employee-reporting rates have increased 56 percent over the last seven years. That is a significant statistic and shows the importance of employee reporting systems and the value that employees place on such systems.

In another important finding, NAVEX noted that employee reporting rates were higher in those organizations that use incident management systems to collect and analyze all available employee concern data, including walk-in complaints, email and more sources.

A company that is committed to maximizing employee communications, and using such data to inform the company’s operations is a company that is committed to its employees. That sounds like a tautology but it reflects an important commitment. A company that wants to know about employee morale, employee concerns and employee ideas is, by definition, a healthy company. By encouraging speaking up, a company is sending an important message – “we want to know your concerns and we intend to respond to them.”

A company’s commitment has to stretch well-beyond collecting and analyzing data – it has to take the data, learn from the data, and respond to concerns. If the data shows significant employee concerns surrounding a specific operation or geographic area or office, the company has to respond and remedy the concern. If the company fails to follow through, the bond of trust between the company and its employees may be broken.

Successful companies have to make sure that their employees are productive, satisfied in their jobs, and supportive of the company’s mission. A two-way communications system is critical to make sure that company leaders and employees listen and learn from each other, and respond to each other as well. It is easy to identify companies where this bond is broken or weak; it is easy to identify companies that have a robust bond in this area where employees are productive and content.