Do you still remember what you had for lunch last Friday? If, impressively, you said yes, how about lunch the previous Friday, or on a Friday 11 months ago?
It might seem a strange question, but that’s the kind of total recall that compliance teams ask of their colleagues across the company when they run their annual survey about the corporate compliance program. Interactions and events might have occurred in Q1, but the departments still waits until December to ask for feedback.
This is often too little, too late. Especially as it’s even harder to answer, “How was your lunch?” “Were you happy with it?” and so on. And when these vague queries are landing in the inboxes of managers preoccupied with targets and deadlines, they would be unlikely to discuss each ingredient, and far more tempted to reply “it was good” or “I didn’t like it” and quickly sign off.
Compliance teams could learn much more from their business partners if they did just do two things they generally fail to do now: ask at the right time, and ask the right questions.
Recognizing this challenge, the compliance team at a big airline in CEB’s networks is exploring a new method designed to elicit specific information that will help Compliance improve more rapidly.
Speed it Up
The most striking thing about the airline’s process is how much quicker it is. Most compliance teams might conduct a risk assessment in, say, January, an investigation in February, due diligence on a third party in April, and then send their annual feedback survey to colleagues in December.
The airline’s compliance team, however, always asks for feedback one week after completing any work for colleagues. Their memory is still fresh, and it makes it easier for compliance staff to track progress throughout the year.
Also, the compliance team only sends these rapid-response surveys to people who participated in the particular activity, as that makes it easier to track results and send out reminders when necessary.
A smaller group is likely to be more responsive. If a survey goes out to the entire company, some employees might think, “other people will do it, so I don’t need to.” But if the survey only goes to a small group with a specific request, they will be more likely to prioritize it.
Ask Specific Questions
Because each quick poll refers to a specific interaction, Compliance can cut down the number of questions, reducing the burden for both survey creators and respondents.
The team designed the survey to focus questions on the details of the engagement. To boost the number of useful responses, the team tailored its survey in three ways.
Make it short: Compliance limited the number of survey questions to six, a huge cut from the more normal pages and pages of text. This frees up respondents to reflect on past programs in detail.
Ask about value and burden: Rather than asking vague questions like “how would you describe Compliance’s performance over the past year?” or “rate your satisfaction with the compliance investigation process,” the team concentrated on two things: the value and the burden Compliance created for employees.
It reinforced an important message that when people realize the value of complying with policies – such as lowering the risk of lawsuits – they are more likely to cooperate.
But adhering to policies and laws also inevitably involves some additional work. It’s important for Compliance to understand how much extra effort this means for employees. In general, employees who perceive low burden are more likely to retain training messages and to report observed misconduct than those who perceive high burden (see chart 1).
The compliance team specifically asks about how much disruption Compliance created for day-to-day business. In this case, Compliance is able to get a sense of how to alleviate that burden in the future.
Chart 1: Impact of perceptions of burden on compliance outcomes Change in outcomes between employees who perceive Compliance as low versus high burden* Source: CEB 2016 RiskClarity
* – Assessment of how much “compliance and ethics requirements (training, approvals, documentation, etc.) slow ability to achieve my business objectives.”
Seek open feedback: The survey seeks to understand negative impressions. Respondents are required to comment if they select any of the bottom three answers – “Neither Agree or Disagree,” “Disagree,” or “Strongly Disagree” – on a five-point scale. Employees can speak up about concerns or dissatisfaction, and also offer constructive advice.
When Compliance sees a common issue raised in responses, it’s easy to go to people who made such comments for more details if necessary.
A Few Things to Keep in Mind
When planning for a similar assessment in your company, remember that if you are concerned about survey fatigue, you can also collect detailed feedback in other ways, such as in one-on-one discussions with employees, in person or over the phone.
The survey also asks respondents to rate Compliance staff, of which results will go into the formal performance reviews. You could leave this part out if you’re concerned about possible anxiety among Compliance staff.