Corporate Compliance and Ethics Week, which is May 6 through May 12 this year, is a time for organizations to thank employees for their commitment to compliance and ethics in the workplace, raise awareness of program and resources, educate employees on specific issues, and share tips and ideas for engaging employees, according to the Health Care Compliance Association (HCCA). HCCA urges its members to commemorate Corporate Compliance & Ethics Week, themed “Think Compliance First,” noting that it is a great opportunity for organizations to gain exposure for their compliance training activities. In the May 2012 issue of Y-Comply,* DeAnn Baker, CHC, CCEP, CHRC, Managing Director, Compliance Advisor Specialists, LLC, explains that “think compliance first” is accomplished by contributing to the development of a “Do the right thing” culture. To understand how to contribute to such a culture, Baker recommends evaluating the following terms:
Culture is the set of shared values and goals that an organization follows. Culture is what sets an organization apart from its peers.
Guidelines for organizations address requirements for designing and implementing effective compliance programs, including the need to create an ethical culture. The guidelines state: “To have an effective compliance and ethics program, an organization shall: (1) exercise due diligence to prevent and detect criminal conduct; and (2) otherwise promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.”
Values are often wide-ranging ideals regarding the right course of action. Values give us a sense of what is right and wrong, and help us to know the “right course of action” to take.
A value system is a set of consistent values and measures. There is an old saying that what gets measured gets done. Organizations communicate their value system through written standards of conduct, often referred to as a Code of Ethics or a Code of Conduct. These documents are the foundation of an organization’s policies and procedures and provide statements of the intention to comply with requirements it must meet.
Compliance programs are systematic procedures established by an organization to ensure that requirements of the regulations imposed by a government agency are met. One of the purposes of a compliance program is to help create a “Do the right thing” culture.
Incentives, similar to a value system, consist of values and measures. It is helpful if management ties workforce incentives to expected performance. The guidelines for designing and implementing compliance programs also address incentives. The guidelines state: “The organization’s compliance and ethics program shall be promoted and enforced consistently throughout the organization through appropriate incentives to perform in accordance with the compliance and ethics program.” An example of compliance activities that can be measured and can incentivize is the participation of the workforce in assigned compliance education and completion of certain policies and procedures that address the organization’s risks.
Baker concluded by saying that “Current policies, procedures, and education help develop a well-informed workforce and a ‘Do the right thing’ culture. Everyone has a part in creating an ethical culture, whether it is incentivized or not. All workforce members are responsible for reviewing policies and procedures, participating in assigned education, reporting misconduct or illegal activities, and carrying out their responsibilities in alignment with the corporate values that are in accordance with rules, laws, and standards.” When everyone does their part to “do the right thing,” they are “thinking compliance first.”
*Y-Comply, a compliance-related article issued four times annually to HCCA members, is intended to help HCCA members communicate the value and purpose of compliance and ethics to the general workforce.