The formula for good compliance

Organizations are successful when they can make good decisions quickly in an increasingly complex regulatory environment while complying with regulations. PLLOB® makes this possible, as it makes good compliance easy to remember and simple to follow. And what is “good” compliance? Good compliance brings rules, values, principles and risks into a good balance that is put into practice.

PLLOB explained in 96 seconds

Press

Does this promote our reputation?

With this question PLLOB® covers the publicity test.  When issues that do not pass the publicity test go public, they…

Leadership

Does this represent our values and make us a role model?

With this question PLLOB® makes clear that every employee can be a role model. Managers are role models whether…

Legal

Does this comply with our company policies and the law?

With this question PLLOB® establishes not only the connection to compliance with law, but also…

Others

Does my personal network agree with this?

With this question PLLOB® incorporates the personal environment because it allows managers to…

Belly/ gut instinct

Does this give me a positive feeling?

With this question managers test their gut instinct where they can cover a great range of…

Press

Does this promote our reputation?

With this question PLLOB® covers the publicity test. Here the manager will have to consider a hypothetical situation. When issues that do not pass the publicity test go public, they usually cause severe reputational damage.There are enough real life examples that clearly show how noncompliance has caused severe damage to an organization’s reputation as the noncompliance became public. If the manager is uncertain about the result of the test he will approach a colleague or a communication expert. Once the organization’s reputation is damaged, confidence in the company, its products and the people who stand for the company may suffer. Damaged trust is difficult to rebuild over a long period of time. Warren Buffet is rumored to have said: “It takes twenty years to acquire a reputation and five minutes to lose it. If you keep an eye on that, you act differently.” Things can become public in various ways. Whistleblowers might place information on respective internet platforms or simply send an anonymous letter to the media (particularly where companies lack an established, professional whistleblower reporting system).

Leadership

Does this represent our values and make us a role model?

With this question PLLOB® makes clear that every employee can be a role model. Managers are role models whether they want to be or not. Consequently, when they are acting with attention to compliance others imitate their behaviour and attitude. Managers can also lead by example and “pllob” decisions together in a team, by applying PLLOB®. Managers can ask one another if they have already “pllobed” what they consider to be a critical decision of a colleague. PLLOB® thus becomes a self-evident and natural part of the decision-making process. It then serves as a compass for compliance for all employees. If an organization has agreed on common values, they can be easily integrated into the daily work via PLLOB®.

Legal

Does this comply with our company policies and the law?

With this question PLLOB® establishes not only the connection to compliance with law, but also to internal organizational rules. The prerequisite is, however, that the internal rules are written in such a way as to communicate clearly their purpose and meaning. Absent rules, processes, instructions, and experience PLLOB® provides a backstop common sense structure for employees and managers to orient themselves in addressing compliance. PLLOB® raises the questions that need to be considered, and in so doing reminds employees and managers that it may be useful, or even necessary, to involve other disciplines in decision-making. If the questions cannot be readily answered, they will ask for advice.

Others

Does my personal network agree with this?

With this question PLLOB® incorporates the personal environment because it allows managers to test critical decisions for acceptance in a limited public context within a protected framework. If the decision is not accepted in this environment, this probably indicates the need for stakeholder management. There will also be decisions that (at least for the moment) can not be accepted and still have to be taken. In this case, the employee is attuned to it through PLLOB® and consciously makes the decision. If there is a confidentiality requirement regarding the transaction to be assessed, this must and will be observed. Within an organization, sharing information to apply PLLOB® will generally not be a problem.

Belly/gut instinct

Does this give me a positive feeling?

With this question PLLOB® asks managers to test their gut instinct where they can cover a great range of potential noncompliances. The popular saying rightly says that gut instinct seldom deceives. If managers follow their gut instinct they will test whether they can “look in the mirror” after they have made a decision. They will also ask themselves whether they would take personal responsibility for consequences of their decision. The question of gut instinct leaves managers with an afterthought when supposedly pragmatic solutions transcend red lines. As the last test point of PLLOB®, the gut instinct has an important function as a last resort backstop. It uncovers potential noncompliance that otherwise could fall through the net.

When will you PLLOB® your next decision?

Why a formula for good compliance?

The focus of most companies today is still on documenting their compliance work. In the event of compliance violations, this documentation is intended in particular to serve to relieve the executive bodies of their liability. The common compliance measures cost a lot of time and their positive effect on good compliance in particular in the sense of preventing compliance violations is increasingly questioned. Without doubt, mere documentation compliance (“paper compliance”) is “yesterday’s news”. What is decisive instead is that the attitude towards compliance and thus the behaviour in the company changes. With PLLOB®, this is exactly where you start.

How does PLLOB® work?

PLLOB® can be used as a nudge due to its shortness and design or as situational reminder of good compliance. The effectiveness of nudges is supported by studies. (See also Richard H. Thaler/ Cass R. Sunstein; Nudge, How to initiate wise decisions) Richard H. Thaler is an economics Nobel Prize winner 2017. PLLOB® reaches employees ideally where decisions are made or discussed and acts as a situational reminder of good compliance. PLLOB® thus brings compliance to the point and to the memory at the right time.

You are asking yourself how this works…

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