An equally entertaining and informational blog post shared by Tom Fox on his FCPA Compliance and Ethics Blog correlates the story of the Charlie Brown cartoon It’s the Great Pumpkin with lessons in process validation and oversight. As Fox notes in his blog: “In the compliance world, process validation comes through oversight. Two of the seven compliance elements in the US Sentencing Guidelines call for companies to monitor, audit and respond quickly to allegations of misconduct.” And, where many companies are lacking is in on effective monitoring.
In our experience, the challenge many companies face is integrating monitoring activities into their operations without increasing headcount. One successful method is to use the process of monitoring for more than compliance. It’s a management maxim older than the great pumpkin that you get what you measure. Thus if you use your monitoring process to measure not only compliance but also performance related metrics you can drive business value.
Use the resources designated for process improvement to also drive the compliance effort. This is especially effective in organizations that drive process improvement with data analysis. It’s relatively easy to add compliance related analytics and achieve anti-corruption monitoring.