Blog Post

The Archer’s Paradox of Compliance Communication


Raina Verma, CFE

The archer’s paradox explores the idea that in order to hit your target, an arrow has to bend around the bow. In order to achieve this, you must have an arrow with the right flexibility. An organization’s communication related to anti-fraud policies and professional integrity, which can include topics like conflicts of interest, employee code of conduct, insider information, managing confidential information, whistleblowing and hotlines, and more, should aim to tackle and reduce fear, nervousness and whispers. Every individual within an organization should feel comfortable bringing up a potential ethics issue.

So if the aim of your organization’s communication is to remove fear, think of the archer’s paradox. Your communication should be flexible, willing to bend and reshape through constant communication, as well as by demonstration of what is being discussed. Just like an arrow bends back and forth several times before meeting its target, we need to repeatedly discuss, train and remind employees of our values in order to advocate the importance of professional integrity.

Success of a training program will not come with a one-time delivery and formal sign-off by employees, but by repeating the message over and over again, in many different formats. Mastery of a training program only occurs with its continuous journey.

Where do organizations begin building their compliance program?

The most important piece of any compliance program is a detailed communication plan.

What we usually see:

  • An organization publishes their policies on a shared portal and requires employees to mark policies as “read.” This exercise suggest that the company has made employees aware of the policies but does not indicate any true adoption of the policies.

What we need to see:

  • An organizational culture that demonstrates professional integrity as a core value. This message is delivered with a well-thought-out communication plan and a continuous journey for each employee.

How do organizations plan and communicate?

Communication is not a one-time exercise and as the word suggests, it is an imparting and exchanging of information. Organizations should build in-house expertise in anti-fraud and financial crimes compliance in relation to the communication of the policies.

I tend to see communication plans that relate to policies where professional integrity is not prioritized or given the significance and weight it truly requires and deserves. However, when a breach or perception of a breach is addressed, there is a substantial and noticeable disciplinary action against the employee. In some instances, the only exposure an employee has had of the policy relating to the incident is from the “mark as read” exercise.

Organizations should, instead, aim to regularly share information with employees. Sharing information is more than publishing an internal paper or memo, but breaking that paper down, simplifying it, giving scenarios and requesting feedback. When an organization creates an entire awareness program, it opens doors for employees to speak up on compliance issues.

Most often, organizations issue a sporadic roll-out of anti-fraud training, which can be in house or may include hiring an external party. Things like flyers, place cards, emails and newsletters are helpful, but without a plan, without a vision toward a continuous journey, these items can feel like an afterthought. If there is no cohesive communication plan, or there is any sort of inconsistency in the messaging, it will be difficult for employees to trust employers.

In fact, it can heighten skepticism in relation to financial crime compliance. So, if organizations stay focused on continuously and regularly discussing uncomfortable hypothetical scenarios, when a real situation arises, fear of retaliation is reduced, and the employee is empowered to take action. This strikes a balance between what is disclosed and how it can potentially impact performance of the employee or the organization.

It is not one department’s responsibility. It’s not one employee’s responsibility. It is a key message at every level.

What do we lack in training programs?

Where I often see training programs fall short is the customization element. Each employee has an individual level of access based on what their role and responsibilities are in an organization. So why wouldn’t we customize our compliance communication to the audience that will be listening to it? What we tell employees on paper and what we tell the employees on the ground are both very important. The art lies in the delivery and touching on aspects that are relevant to a specific audience.

While the pandemic has been challenging and heartbreaking in so many ways, it has also forced many organizations to change their methods of communication. We can learn from this crisis, and communicate more effectively. Even if you have a policy in place but a poor communication plan, you still have a good problem — at least you know where to start!

Once communication has kicked off and you have voices coming back from employees, remember the archer’s paradox. If you stay flexible and willing to adjust, eventually you will hit your target.

SOURCE: ACFE Insights – A Publication of the Association of Certified Fraud Examiners

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