With many, or maybe all, of your employees now working remotely, ensuring engagement with your compliance program is more important than ever
Like most animals, we humans are creatures of habit and of structure. Routines, like coming into the office everyday, keep us both physically and mentally moored, and even out of trouble. For many, the coronavirus pandemic and resulting remote-work situation have thrown this structure out the window. What an enterprise financial firm has to ensure is that the employee compliance practices that keep the organization out of trouble don't go out the window, as well.
"The regulators may be working remotely, but they are working," says one compliance officer for a large asset management firm, addressing the effect of the COVID-19 crisis at the recent Star Virtual US Forum. "We all know, after the markets settle, that FINRA, the SEC, and all the regulators will be back on their horses, investigating anything they can find. Any abnormalities or anomalies that took place. Anything even slightly suspicious." With this grim prognostication in mind, we offer three ways to increase employee engagement with your compliance program and keep them engaged—for as long as the global lockdowns continue and beyond.
1. MAKE MORE DATA MORE EASILY AVAILABLE
A culture of accountability that pervades every level of the organization. It's what every firm dreams of. A switch from the notion of 'this is what I have to do' to 'this is what I ought to do.' A true culture of accountability means you don't have to prod people as much to get things done. This is a lofty goal but an achievable one, and there are practical steps you can take to get there.
"An initiative at our firm," offers one veteran compliance officer who spoke on the subject of personal accountability at a recent Star Conference, "is to get greater accountability at the supervisory level and in upper management. To achieve this—and really to get folks at every level of the organization more engaged—we're trying to get them more data. We believe this will make them better informed and therefore more accountable overall. Accountability at every level is important." And if you can deliver this data in immediately relevant and easily accessible ways—if you can make the task of getting to it less onerous, make it so that it's not even a task—then you're taking a critical step toward making compliance an integral part of firm culture.
The STAR Platform has long offered a suite of in-app reporting tools that allow you to configure your own reports and schedule and distribute them. But the next level of data visibility and reporting has now arrived in the form of embedded analytics, or dashboards. Star Compliance Dashboards offer near-real time data visibility for gifts, entertainment, and certifications. By automatically surfacing deep data, there's less chance of important data points or trends being missed. And easy accessibility means the scanning of this data is more likely to become part of the day-to-day routine—helping in a pragmatic way to create a culture of accountability.
2. TRAIN REMOTELY & MAXIMIZE YOUR PLATFORM
"We're a small shop. Ensuring participation, in some respects, is easier for us because we can do one-on-one training with every employee on their first day. So I'll sit down with them, walk them through the system, and they can put a face to compliance right off the bat. That said, we're trying to move away from handholding. We do a lot more with automation now." This from another senior compliance officer speaking at one of our Star US Conferences, and a more succinct case couldn't be made for the possibilities that web-based, highly automated compliance platforms offer to firms of any size, particularly in the new normal of remote-work.
Conflicts of interest detection and mitigation platforms like the STAR Platform make it easier than ever for compliance to offer virtual walkthroughs of compliance software functionality and even remote training on it. The STAR software is really just waiting to be leveraged in this manner; it's intuitive, to maximize adoption and use, no matter what the distance between employee and compliance team is. You can easily link to files and attachments throughout the system, in places end users are bound to frequent, like the system homepage. You can easily add user guides, so self-training is also a real possibility.
"Optimizing the user experience by optimizing the user interface. Grouping together particular functions. Being better about key words. Being able to deliver different types of communications within forms. Inserting little phrases that align with firm policies and procedures. Making small customizations like these to the compliance platform can make a huge difference."
3. BE FLEXIBLE HOWEVER & WHEREVER POSSIBLEIn the UK, the FCA and the PRA have gone out of their way to let it be known that they understand the pandemic is causing operational issues for firms (read about the FCA statement here and the joint FCA-PRA statement here), and have laid down loosened guidelines for how firms should think about compliance in the current climate of lockdown and mass remote-work. But yet another senior compliance officer addressing the issue at the recent Star US Virtual Forum was taking no chances: "We made the decision we wouldn't be making changes to our code of ethics and that we wouldn't be making any exceptions. We feel that's a slippery slope. This is the time to keep the policies as they are. We know that people have a lot going on personally and professionally, but relaxing our code is just not the thing to do right now."
One of the ways you can introduce flexibility into your compliance program that doesn't risk bringing on potential regulatory wrath is employing a mobile app as part of your compliance solution. Mobile compliance apps that work in conjunction with mother platforms have varying levels of capability, depending on the vendor, but the idea is to bring true desktop functionality to a mobile device and make compliance requirements simpler and easier to fulfill.
The STAR Mobile app is a native app. It was designed from scratch to offer true STAR desktop capability on a mobile device. STAR Mobile currently offers full personal trading and gifts-and-entertainment functionality—the same as is available on the STAR desktop app. Employees can pre-clear trades and report gifts and entertainment spending. Supervisors can review escalated requests. Device-level notifications management means staying on top of high priority tasks is easy, and best practice network and device protocols mean secure data transport and secure local-device storage. Before pandemic protocols and remote-work became the norm, mobile compliance was already an idea whose time had come, and had the potential to take employee engagement to new levels. Functionality like this has suddenly become very near indispensable.