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The Medium is the Message Marketing Compliance & Ethics to Your Workforce

When Attention Spans Are Short

Barbara Harmon, CCEP

Compliance and Quality Assurance Lead, Alyeska Pipeline Service Co.

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2013 SCCE Compliance and Ethics Institute, Washington, DC

Overview

• Channel surfing the program schedule: develop a compliance and ethics communication plan using a multitude of media

• Work smarter, not harder: engage employees outside of the C&E group to get the message out

• Less is more: how to keep your messages simple

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an effective communication & training program”

And the Federal Sentencing Guidelines said, “Let there be…

The Compliance & Ethics Communication Plan

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THE COMMUNICATION PLAN

• What is the message I want to get across? (e.g. “Don’t Steal”)

• Who is my audience? (What channels do they watch?)

• What communication medium (media)

• What is the time slot? (Frequency? Time of year?)

• Who is the sponsor?(e.g. Brought to you by the CFO)

• What channel/ theme will the audience relate to?

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Message

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Nice buns

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Audience - 3 Generations Working Together

GEN-Y / MILLENNIALS (25%)

• 1985 – 2005

• The Technology Generation

GEN-X (32%)

• 1965 - 1984

• The MTV Generation

BABY BOOMERS (38%)

• 1946 – 1964

• The Workaholic Generation

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• Peer to Peer Social Collaboration • Wants a Coach, Not a Manager • Seeks Stimulation & Engagement

• Independent, Resourceful, Self-Sufficient, Flexible

• Appreciates Having Fun at Work

• Uncomfortable promoting knowledge sharing

• Age + Tenure = Experience • Defer to hierarchy

Medium/Media

“The content of the medium is a juicy piece of meat carried by the

burglar to distract the watchdog of the mind… people tend to focus on

the obvious (the video, the book, the photo…), but in the process, they

largely miss the structural changes in their affairs that are introduced

subtly over long periods of time – values, norms and ways of doing

things change because of technology.” ~ Marshall McLuhan, 1964, Understanding Media, Routledge, London

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The Medium Shapes the User’s Perception of the Message

FILM • Linear • Everyone participates

at same rate (beginning, middle, end)

WEBSITE • Fluid • User decides how to

consume information and reach conclusion

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Medium/Media

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• Memos • Newsletters • Handbooks • Brochures • Business cards • Photography • Screensaver slides • Posters • Desk-drops • FAQs • Meetings • SWAG • Headlines

• Video • Music • Email Message from

Management • E-Bulletins • E-News • Forums • E-Learning • Audio (Podcasts) • Games • Cartoons • Comics • Brown-bag Sessions

• Event-based communication (Compliance & Ethics Week)

• Recognition Gala • Real-life Scenarios • Interactive On-line Tool

Customized Path by Job Function and Location

• Wikis • Blogs • Focus Groups • Coffee with the C-Suite

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Time

• Weekly/Quarterly/Annually

• Busy season vs. less busy season

• Compliance and Ethics Week (or Month)

• Breaks (Coffee, Lunch, After-Hours)

• New Hire On-Boarding

• Company/Department/Staff Meetings or Supplier/Vendor Summits

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Sponsor

“The most effective CEOs take every opportunity to address business matters in the context of the company’s core values, which often include a commitment to ethics and integrity…staff meetings, speeches, employee gatherings, holiday celebrations, etc.

CEOs must constantly remind senior managers and employees alike that they are expected not only to follow all laws, rules and regulations, but to make decisions that they would be proud to share with their families, friends, and local newspapers, regardless of whether those decisions maximize revenue.” ~ Eric Feldman

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Channels

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MusiC & E

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The Communication Plan December – Gifts & Entertainment January – Safety

It’s an Ethical Life 3 Minute Info Video Sponsored by The Business Practice Office

When in Doubt, Chicken Out 3 Minute Info Video Sponsored by The Safety Department

Don’t Accept Inappropriate Gifts Screen Savers Sponsored by The Business Practice Office

Hold the Rail or Fail Cartoon in Company Newsletter Sponsored by the Safety Department

March – Risk April – Contractor Compliance

Risk Compliance Brackets Risk Opinion Survey Sponsored by Enterprise Risk Management

You Make the Call Team Discussions of Ethical Dilemma Sponsored by The BPO

Loss of Reputation = Unacceptable Risk Email from the CEO Sponsored by the Boss

Why is Compliance Such a Big Deal Here? E-News Article Sponsored by Supply Chain Management

September – C & E Week October - Fraud

The Compliance Universe Department Info Booth Sponsored by the CCO

Auditor for a Day Cross-Department Training Sponsored by Internal Audits

The Daily Quiz Email Key Points Sponsored by the CCO

Expense Report Jeopardy PowerPoint to Sales Division Sponsored by the CFO

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C&E Sports

Gifts & Entertainment

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You know, Boss –

you can stay free

at my condo at the

ski resort any

time!

And after our software

presentation, please

keep this iPad as a token

of our appreciation…

absolutely no obligation,

of course!

Sweet! My

favorite contractor

just sent me

two tickets to the

Super Bowl…

I love my job!

Ask yourself: Will I be influenced by accepting it? Will others believe accepting it has influenced me? Will others believe that someone received an unfair advantage?

Hey, while you’re thinking

about renewing our

contract, why don’t I come

over and help with your

kitchen remodel project?

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“Hold the Rail or Fail”

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Tip: How to do cartoons/ comics when you don’t draw

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SCCE rocks!!

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Compliance Risk Brackets

FINAL FOUR

COMPLIANCE RISKS

Conflicts of Interest

Contractor

Noncompliance Property Theft

Fraud

Personal Data

Privacy

Proprietary

Information

Environmental

Protection

Workplace Safety

Workplace

Violence

HIRD Political Activities

Anticorruption

Data Security

Records

Management

Labor/HR

Insider Trading

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C&E Sports

Compliance Risk Brackets

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C&E Sports

INTRODUCTION You are invited to participate in our company’s Compliance Risk Brackets opinion survey. You will choose which compliance areas you think pose the greatest risk to our company. The survey can be done anonymously, but if want a chance to be in a drawing for a fabulous prize, please submit your name/contact number at the end of the survey. Round 1 will take the Not-So-Sweet-Sixteen risks down to the Elevated Eight. Round 2 will pick the Final Four Risks. At our company, a Compliance Risk is defined as a potential event that may lead to legal or regulatory sanctions, damage to the company’s reputation, personal injury and/or financial loss as a result of a failure (or perceived failure) to comply with applicable laws, regulations, or other regulatory commitments.

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Compliance Risk Brackets

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C&E Sports

Conflicts of Interest

Political Activities

Select which of these two risk types you think would be more likely to occur at our company Conflicts of Interest (examples: employee accepting inappropriate gifts, gratuities, travel or entertainment expenses from a vendor; using your company position to influence the hiring of a relative) Political Activities (example: using company resources to give the appearance of a political endorsement)

Comments (optional)

A CODE FOR ALL

SEASONS Questions? Winter, Spring, Summer or Fall

All you have to do is call…

Our Company HelpLine (800) xxx-xxxx

MusiC & E

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The Music Video Competition

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http://www.youtube.com/watch?v=yjGBSZs4y6s

MusiC & E

Compliance & Ethics Week

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ACE Soap Fables

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A Compliance & Ethics (ACE) Soap Opera Mash Up With Aesop's Fables

Using Other Departments To Get The Message Out

…but first a word from our sponsor….

The manager/department overseeing the risk area delivers the message

• Compliance & Ethics Week booths

• Video key points

• Brown Bag Lunch/ Morning Coffee Chat/ Comm Meeting

• Emails (Tip – even if it wasn’t originally on your comm. plan, take credit after the fact)

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What compliance and ethics professionals say:

What CEOs hear:

IF WE CAN GET LEADERSHIP TO WALK THEIR TALK AND REINFORCE A STRONG COMPLIANCE AND ETHICS MESSAGE FROM THE TOP TO THE BOTTOM, OUR EMPLOYEES WOULD DO THE RIGHT THING, OUR COMPANY WOULD BE A GREAT PLACE TO WORK, AND WE WOULD BE IN LINE TO BE RECOGNIZED AS ONE OF THE WORLD’S MOST ETHICAL COMPANIES!

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Blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah,

blah, blah, blah, blah, BOTTOM, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah,

LINE blah, blah, blah, blah, blah,

blah, blah, blah!

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5 Things Every Employee Should Know About Our Compliance and Ethics Program

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Tips • For brochures, Powerpoints, newsletters, screensavers, posters, etc.

KEEP IT LIGHT vs.

• Do desk-drops in person during business hours

• Videos = 3 mins. or less; use different angles and movement

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Key Points • The medium through which a message is experienced shapes the

user’s perception of the message.

• Repeat, repeat, repeat – Provide the same message in a multitude of mediums because people vary in the ways they take in information

• Today’s employees seek to be “Edu-tained” – don’t be afraid to use humor, creativity, and fun

• Get other departments to steward compliance

• Keep it simple and let the medium do some of the communicating.

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Questions ~ Comments

REFERENCES

• Costello, R. and Bliton, D. “Assessment of the Educational Visual Storytelling at the Smithsonian”, Interservice/Industry Training, Simulation and Education Conference, 2009.

• Feldman, E. “The Seven Biggest Mistakes Companies Make That Erode Ethical Culture and Destroy Reputation”, Compliance and Ethics Professional, Oct/Nov 2011

• Gross, J. “The Medium is the Message”, Smashing Magazine, July 4, 2011.

• McConnell, R. “The March Madness Compliance Risk Assessment Bracket”, Corporate Counsel, March 21, 2013

• Tolbize, A. “Generational Differences in the Workplace”, University of Minnesota, 2008.

• http://legalcareers.about.com/od/practicetips/a/Babyboomers.htm

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