[00:00:00] Speaker A: Hi, everyone. The Business Ethics Leadership alliance has questions and we have answers. I'm your host, Bill Coffin. Welcome to another Bella Asks episode of the Ethicast.
One of the best benefits of being a member of the Business Ethics Leadership alliance or bella, is that if you have any questions at all about ethics and compliance, you can submit them to Bella's concierge service and one of our internal experts will provide an answer and direct you to a helpful resource for more information. Now, most of these requests speak to the broad challenges facing Bella members and by extension, the wider ethics and compliance profession. That's why we're using this show to thematically respond to high level questions from the Bella community.
And joining us once again to answer those questions is Bella chairman Erica Salmon Byrne. Erica, it's good to see you again. Thank you for joining us.
[00:00:55] Speaker B: Oh, Bill, it's my pleasure. I'm happy to be back.
[00:00:58] Speaker A: Well, our next question is a communications question and it reads, how do I use site visits for communicating E and C messages? This is a great question because when I interview folks they often talk about the strategy quite a lot. So I'd love to hear what you have to say about it.
[00:01:13] Speaker B: Yeah. So there's two ways to think about site visits and obviously they were something that took a pause during the pandemic because we, we couldn't do site visits. But they are starting to return. Not in the same level or at the same velocity as pre pandemic, but we are definitely seeing compliance teams being able to get out into the field to locations around the globe as needed. So the way you can think about site visits is you can think about your formal work at the site and you can think about your informal work at the site. So from the formal side of things, we often see compliance professionals using the time to do short training sessions. There is tremendous value value in live training. So can you get a group of people together and do a short session on a particular risk? I am a huge fan, as you know, Bill, of case study or tabletop style training for particularly four key risk areas, particularly for senior leadership teams. And I was very happy to see the Department of Justice in the September updates to the evaluation of corporate compliance programs guidance. They put in the idea of learning from other people's mistakes, either your own mistakes or your peers mistakes. And so I would just emphasize to everybody listening, if you are on site and there has been an issue in your industry or there has been an issue in your company and you have a chance to take that fact pattern, take a step back and Ask yourself, could it happen here? How could it happen here? What would it look like? What would be the early warning signs? What would this particular location potentially be seeing in their third party data, in their quality data, in their interactions with clients? That would give us a sense that the same issue might be happening inside of our business so we can get out in front of it, do that. Right. And I would also say, you know, the question that came in was E and C communications. I am really encouraging the companies that we work with to stop thinking about training and communications as two separate things. What you're aiming for is employee engagement with risk topics. And so, yes, a case study exercise or a tabletop exercise is a little bit closer to training, but it's all about employee engagement with risk topics. And so the more that you can get your leaders in a particular location to think about a fact pattern to practice. Right. We do this for data breaches, we should absolutely do this for other kind of risk topics. And so that would be one of my recommendations. On the formal side, on the informal side, just walking around, talking to folks, introducing yourself to people you don't know. Right.
Have a lunch with new employees that have joined since the last time you were at the location.
Make yourself available, leave the door open for whatever space you're in.
Sit in an open space if you can, sit in the cafeteria, if you have one, sit in the break room. Those are all ways that you can think about trying to engage employees informally. Because so much of the work we do is relationship building. And so to the extent that you can work on building relationships, it's definitely time well spent.
[00:04:24] Speaker A: When you're going on site, your time is super, super valuable. Every moment counts and you're going to want to make the most of it. Is there any particularly productive pre work that you would recommend people do before they go on a site visit to make sure that they get the absolute most benefit out of the time they have during the visit?
[00:04:40] Speaker B: It really depends on the reason for the site visit. Right. So I want to bucket this into two pieces. If the site visit is really a site visit, you have, you haven't been to this location in a while, you want to go down and engage with people. That's going to be a slightly different exercise for that. I would look at metrics coming out of that particular region. Right. How are you looking on training completions? What are your culture survey results telling you? What have you seen in terms of employee turnover? Are there particular pieces of the M and A landscape that you want to think about? For this particular location, have you recently bought a company and this is your first chance to go down and meet the people from this newly acquired entity. So a lot of it needs to be driven by the reason you're going. If you're going for an investigation, different thing, right? That's a different, you know, that's a, that's a different exercise. If you're going as part of an audit team, different exercise, right? So a little bit of it depends upon why you're doing the site visit. If it's really just a drive by, say hi kind of a thing, then from a pre work perspective, you want to gather all the data you can about what's been happening at that, in that particular location over the last six months or the last year, whatever the case may be. What are the key regulatory things that might be happening in that country? Is there a recent piece of legislation that you want to be on top of that might be driving some of the conversations? So those are, those are some of the things I would recommend thinking about.
[00:05:57] Speaker A: Erica, as always, thank you so much for sharing your insights with us. We really appreciate it and I know the Bell community is really grateful that you're sharing your thoughts with us on these.
[00:06:06] Speaker B: No, Bill, it's my pleasure. And as I say in almost all of these at the end, I love answering these questions. So please keep the questions coming. It gives me an excuse to come back and talk to Bill and give you all my thoughts on it. So I appreciate it very much.
[00:06:21] Speaker A: To learn more about Bella, please visit ethesphere.com Bella to request guest access to the member resource hub and to speak with the Bella engagement director. And if you have a question that you would like answered on Bella Asks, be sure to use the Bella Concierge service and we'll get to it as soon as we can. I'm Bill Coffin and this has been a special Bella Asks episode of the Ethicast. For more episodes, please Visit the Ethosphere YouTube
[email protected] ethisphere and if this is your first time enjoying the show, please make sure to like and subscribe on YouTube, Apple Podcasts or Spotify. Thanks for joining us. And until next time, remember, strong ethics is good business.
