The ultimate success of a global ethics and compliance program often depends on the ability of local compliance officers to engage business operations in a specific country.  Of course, a global compliance program’s performance depends on cooperation and coordination at all levels, but in many cases, the ability of a local compliance officer to adopt creative and intelligence strategies to engage the business will establish an important foundation for a compliance program.

All the parts of a global compliance program are interdependent, and the failure at one level can be catastrophic to the entire program.  In general, however, an effective local compliance officer on the ground, working closely with business staff, can be very effective in promoting a company’s culture and its overall compliance with the code of conduct and the law.

Local compliance officers face a challenging dance – they have to push their compliance agenda, while maintaining a positive relationship with the business.  It is a delicate dance.  I have observed numerous instances where local compliance officers are able to establish themselves as a business partner by facilitating business compliance with global policies and procedures.  This is where a local compliance officer can make life easier for the business staff and build some goodwill as a true partner.

Business personnel often find compliance policies and procedures intimidating.  Like all of us, our initial reaction to internal bureaucracy is to ignore or look for a shortcut to avoid the perceived “pain” of following burdensome procedures.  Local compliance officers can help business staff by developing checklists, cover sheets, and other materials to simplify the process.  In doing so, the local compliance officer is not altering the compliance obligations but is just making the process a little easier to follow.  Business staff will appreciate such an effort.

Local compliance officers also have to establish their position at the business table.  When business meetings occur, they have to be invited to attend and provide a value-add by providing an important compliance perspective for any new business initiatives or issues.  Again, the local compliance officer can easily establish him or herself as a facilitator to implement business strategies.

Every compliance officer has to understand the company’s business.  This is an absolute requirement – no ifs, ands or buts.  With this knowledge, the local compliance officer will be able to communicate effectively, empathize with business concerns, and develop strategies that can advance compliance and the business at the same time.

Local compliance officers can serve as an “advocate” for the local business when it comes to compliance issues where local conditions may require adjustment of a global ethics and compliance policy.  Local compliance officers have to pick and choose their battles and seek a waiver from a global policy when there is a compelling reason to do so.  Global policies need to be followed but there has to be a small slice of room to adjust some of these policies to account for local conditions.

Finally, I have observed many local compliance officers develop supplemental training programs to reinforce global training presentations.  It is difficult to conduct global training and ensure that the programs are attractive and engaging.  A local compliance officer, knowing the local markets and conditions, can create training programs that reflect local scenarios that raise compliance issues.