Why a Formula for good compliance?

Overcome “Compliance fatigue/ frustration”

In many companies a cross-hierarchical “compliance fatigue” has spread.  Repetitive training, flood of guidelines, processes etc. contribute to this. These measures cost a lot of time and their benefit is increasingly being questioned. It is complained that despite all efforts, it is impossible to remember all the guidelines and rules. Employees long for understandable and memorable assistance. They regularly want to be compliant, but are often unsure what that means. A concise formula helps enormously here.

New/ different “tone from/at the top”, creating role models

Many companies practice a “tone from/at the top” with regard to compliance and integrity. When compliance cases occur, it is regularly claimed that the violations were not known to the top management. This assertion is often not believed. This leads to accusations of planned misunderstandings and irresponsibility. To effectively prevent such allegations, management must communicate continuously and unambiguously what attitude and behavior it expects from employees and in particular from the Managers with regard to compliance and integrity. This also conveys what it means to be exemplary as an employee. A smart formula is ideal for this purpose.

Compliance as (self-) management task

Every employee can serve as a role model, also with regard to compliance. Managers are role models, whether they like it or not. Their behavior and attitude are imitated. This is why “leadership” is indispensable in compliance. Managers can set a good example and test decisions jointly as a team against a compliance formula. One manager can ask another manager whether he or she has already checked a decision – which is critical from his or her point of view – against the formula. Every employee can measure critical decisions against the compliance formula and express doubts using the formula. In this way, the formula becomes a natural part of the decision-making process and fosters a speak up culture. The formula serves all employees as a compass for good compliance. By means of the formula, common values of the organization can be easily integrated into daily work. A self-explanatory formula thus helps every employee to act as a role model for the values of the organization.

Create a clear understanding of  what “clean (compliant) business” means, provide a handy compass

With a smart formula the message: “We only do clean business” gets a meaning because it is clear what “clean” means: “Clean” business passes the formula. A formula should accompany employees in their work as a handy and constant compass for good compliance. In this way, management communicates unambiguously what behavior and attitude is expected in terms of compliance and integrity. This helps to protect companies from serious compliance violations.

Operationalize values/principles, make risk-oriented decisions

By means of a clever formula that incorporates values and principles, these can be brought to life in day-to-day work. They do not remain mere lip service. Risk-oriented decisions are possible with a smart formula. The formula defines the red line that must not be crossed.

Reduce overregulation and create a new culture of rules

A clever formula conveys the claim to employees that “less is usually more”. A short and concise formula actively encourages employees to question incomprehensible or even completely superfluous processes and guidelines in a transparent and constructive manner. In this way, the number of existing guidelines and processes is professionally reduced and what remains has greater acceptance due to its better quality. This establishes a new, better regulatory culture.

Allow and promote common sense

Many claim that common sense has fallen by the wayside. When employees are faced with dilemmatas, they need handy tools to make a good decision. This is where concise questions, in the right order and ideally embedded in a smart formula, help. Thus also the common sense returns.

Using your gut feeling in a professional environment

Most use their gut feeling also in a professional environment and thus support good decision making. Using a clever formula, gut instinct can be focused on the central aspects that are relevant for good compliance. In this way an “informed” gut decision can be made. The gut feeling comes last in the formula and assumes the important function of a “safety net”.

Teach employees when it is absolutely necessary to speakup

Due to the EU Whistleblower Directive of 23.10.2019 (2019/1937), the German legislator has since passed the Whistleblower Protection Act, according to which companies with more than 50 employees are obliged to set up a whistleblower system.
In addition, since 1 January 2023, the Supply Chain Due Diligence Act has required companies with at least 3,000 employees to set up an internal complaints procedure that enables employees and external parties to report human rights and environmental risks or breaches of duty. From 01.01.2024, this obligation will also apply to companies with 1,000 or more employees.
If the whistle is blown via such a system to notify of any compliance-violations, it is often already “too late”. This is also why many companies want to strengthen their speak up culture to avoid serious compliance violations. However, it is difficult to define a uniform standard for when it is absolutely necessary for employees to speak up. A smart formula enables all employees to measure decisions uniformly with regard to compliance and integrity. This means that decisions are not questioned arbitrarily, but if and when they fail the formula. If a decision is questioned by means of a smart formula, all aspects of compliance are “put on the table” without having to use the (un-)word compliance. Thereby a smart formula makes it easier to speak up.

When and how to apply PLLOB

When:  To every professional decision.
How: 1. Check PLLOB yourself.
2. Not sure: Consult!  Colleagues→superior/manager→compliance specialist
3. Concerns: Address it by e.g. saying “Let’s apply PLLOB to this.”

Compliance becomes an integral part of the company DNA

A smart formula supports that compliance becomes an integral part of an organization’s DNA because the formula becomes part of the working language. It verbalizes compliance.  In the sense of: “And what does PLLOB say?” or “Have you already PLLOBed that?!  The person opposite will now think about all the aspects contained in the clever formula. A wise formula is designed to allow and encourage intuitive decisions, which are regularly resilient.

PLLOB® is exactly this formula.