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.
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
The EU Whistleblower Directive of 16 December 2019 is intended to raise the protection of whistleblowers to a uniform level throughout the EU. The Member States have two years to transpose the directive into national law. Many companies already have a whistleblower system or will now have to introduce one. 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.
PLLOB® science and background
Concise questions help making good decisions
The effectiveness of concise questions in supporting good decision making is supported by scientific studies (see https://dash.harvard.edu/handle/1/27419676). With PLLOB® five concise questions are asked that cover the essential aspects of good compliance. PLLOB® can therefore be effective and efficient. PLLOB® brings compliance to the point and to memory.
The colorful PLLOB® logo appears positively
You may wonder why PLLOB® was designed as a colorful logo. The colorfulness is supposed to bring compliance out of the rather “legal-dry” corner. Through the design of the logo and its choice of colors, compliance attracts positive and friendly attention.
PLLOB® acts as nudge
PLLOB® can also be used as nudge due to its brevity and design. The effectiveness of nudges is also 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. A classic among nudges is the speed smiley. Together with Prof. Carmen Tanner from the Zeppelin University Friedrichshafen and the University of Zurich, it is planned to further investigate the effectiveness of PLLOB.
Creating vigilance for compliance is essential
PLLOB® can be used to create a vigilant attitude towards compliance. This makes it easier for employees to recognize unethical behavior in others and in themselves. (See for the importance of “vigilance” https://dash.harvard.edu/handle/1/27419676 )
PLLOB® brings compliance into the organizational DNA
PLLOB® supports that compliance becomes an integral part of the DNA of an organization because PLLOB® becomes part of the working language. This is because with PLLOB® Compliance can be verbalized. In the sense of: “And what does PLLOB® say about it?!” or “Have you PLLOBed this already?!”. The person opposite will now think about all the aspects contained in PLLOB®. At the end of the also intuitive decision-making process, there is an “informed” gut decision, which is regularly resilient.
PLLOB® in practice
PLLOB® ideally reaches employees where decisions are made or discussed and thus acts as a nudge or situational reminder of good compliance. PLLOB® thus brings compliance to the point and to the memory at the right time. Here are some examples:
1. Compliance Gate, situative reminder and digital nudge
Label the final release button of digital processes e.g. business partner screening-, arms control-, software design processes with PLLOB®.
2. Situative reminder and physical nudge
As a webcam cover when skyping and writing and reading e-mails.
On coffee mugs placed in your cantine, meeting rooms or offices.
On coasters placed in your cantine, meeting rooms or offices.
3. As part of daily language
Your organization’s leaders regularly PLLOB® critical decisions in team meetings.
One staff member asks the other, if she/ he has actually PLLOB®ed a critical decision.
Staff speaks up by asking whether PLLOB® has been applied to a critial decision.
4. Compliance-attitude and behavior
Common compliance work is mainly used to exclude liability by generated documentation. Experience shows that compliance cases are not prevented by this. What does PLLOB® do to your organization? It will change in terms of compliance behavior and compliance attitude of employees. Thus PLLOB® prevents serious compliance cases. Finally, if PLLOB® is part of the daily language use and thus accompanies the employees, then compliance is a natural part of the DNA of your organization. This cannot be achieved with training, instructions, guidelines, processes etc. alone. From the perspective of the organization developer, PLLOB® is a powerful intervention.
This is not the only reason why the introduction of PLLOB® should be professionally accompanied and framed.