Architect globally, implement locally

 

Challenge

The client is a multinational company operating in over 80 countries.

The feedback from the business was that compliance was not always an enabler: the staff found compliance hard to understand, there were varying degrees of compliance, and some business groups simply did not implement the required programmes. There was a very mixed view of compliance from the business groups across different regions and a great deal of misunderstanding.

 

Answer

We worked with the client to build a set of Integrity Circles®, which were small group sessions of ten to 15 people. There were two to three sessions held in each country, depending on the size of the business in that area. A vast array of people attended the sessions from all facets of the business.

The attendees were asked to join in on one of the Integrity Circles® at a time that suited them. In some cases, we reorganised attendees to make sure the groups were broad enough. We also made sure that there wasn’t a senior manager in the room that people would feel uncomfortable speaking in front of. (In most cases, we organised a separate session for senior managers.)

All of the sessions broadly followed the same agenda. They were not training sessions, although there was an element of awareness for training. The sessions were designed to:

  • Introduce the compliance programme to many people for the first time and show them our focus
  • Obtain feedback on the compliance programme generally and identify major risks
  • Gain an understanding of the local issues that existed in the market in terms of compliance (e.g. special local laws that impacted the overall programme)
  • Gauge where the company was positioned in terms of compliance against peers
  • Test the whistleblower programme and ensure that people were aware of it.

These sessions were not an audit; they were engaging, open-discussion forums. PowerPoint was rarely used and the group led the discussion unaided.

 

Timeframe

About two months in total. Each in-country session took two to three days, depending on the size of the operation.

 

Why The Red Flag Group?

  • Practical. We are practical and engaging in our sessions in country.  We know how to make people feel at ease and how to engage non-compliance people to talk about compliance.
  • Country and regional experiences. We know the issues in countries and we know what to ask and what not to ask.  We are sensitive to local issues and careful not to give advice 'on the fly'. 
  • Logistical Management. We managed the entire process for soup to nuts in all locations. This included arranging all locations and ancillary matters. 
  • Recommendations.  No one wants just a list of issues, they want to see recommendations.  This is what we provide in every situation in which we are engaged.

 

Deliverables

REPORT

  • Designing the Integrity Circles® and setting up the session objectives
  • Drafting the agendas and arranging locations in our offices or the client offices
  • Attending and facilitating all sessions in country in multiple languages
  • Drafting a report for management on summarizing concerns identified
  • Drafting a gap analysis and areas for improvement across the entire compliance program
  • report out to all participants

PRODUCT

  • Integrity Circles®
  • Whistleblower programme review

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