Today we deal with another essential element for a successful Compliance and Integrity Program: Communication. It is a concept that is of the utmost importance for the implementation, development, and maintenance of any compliance program in Brazil.
Communication is, of course, also critical for Risk Management and Corporate Governance.
Once the organization has approved the Code of Conduct and other compliance policies, it is time to communicate these documents’ existence and content to all employees, third parties, customers, suppliers, administrators, directors, and advisors. In other words, to all stakeholders.
Whenever possible, the organization should communicate in person and via electronic channels, so often used today.
One company had an online journal that was sent to all employees twice a week via group email. Since this initiative was already in place, the company decided to include a Compliance and Integrity Column in the weekly journal.
From then on, each new edition of the online journal included an article that explained and reminded employees of all levels about a specific topic addressed in the Code of Conduct. This strategy was a way to gradually make employees aware of the company’s Code of Conduct. It eventually became part of the business routine, increasing the effectiveness of the Compliance Program.
There are many theories about Communication, some of which may even be questionable. Still, the fact is: what you want to communicate is not always understood by those who receive the message.
It is always worth highlighting the importance of direct and straightforward communication and using a language that can be understood by multiple audiences with different levels of knowledge. This means avoiding technical terms – only known by experts –, or abbreviations that can only be understood by those who are part of the organization.
More technical terms can be used with specific audiences, such as publishing a Competitive Compliance Notice to the Board or the Sales team. However, this is an exception where the technical terms such as “abuse of economic power” or “cartel” actually help jogging the stakeholders’ memory about essential concepts.
Communication campaigns are also very useful in a Compliance and Integrity Program, such as creating a “compliance day” or “compliance week”, and involving various sectors of the organization, or holding events such as “coffee and compliance” as was done by one company to promote an open discussion about the problems identified in each department.
The Compliance Program can use posters with messages and photos of the leaders in each department. It can also use banners, cards, stickers, letters on the home screens of computers, etc. There is a multitude of options, and this is an excellent opportunity to get creative.
Even if a Code of Conduct is excellent, it will probably be of little value if there is no open, repeated – and preferably exciting and attractive – communication strategy.
Edmo Colnaghi Neves is a lawyer and a Corporate Compliance Expert, he is a partner at Colnaghi Neves Consultoria Empresarial, and the author of the book Doing Compliance in Brazil, published by Editora B18.
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