Betsy Wade (bwade@signaturehealthcarellc.com) is the Chief Compliance and Ethics Officer at Signature HealthCARE in Louisville, KY.
Corporate Compliance & Ethics Week is a great opportunity for compliance and ethics professionals to put on their creative hats and cultivate the importance of compliance and ethics in their organizations across the United States and around the world. This year Corporate Compliance & Ethics Week will be held November 7–13, so it’s time for compliance and ethics professionals to start putting plans together to kick off their celebrations.
History and core principle
The idea for Corporate Compliance & Ethics Week came about 19 years ago when HCCA members were discussing how to educate employees about the importance of compliance and ethics in organizations.[1] One suggestion to hold a Compliance Day quickly grew into designating a Compliance Awareness Week. After a few organizations successfully held their own events, the HCCA Board of Directors and the Society of Corporate Compliance and Ethics (SCCE) Advisory Board launched the first National Corporate Compliance and Ethics Week in 2005. For years, the annual event was held in May, but it was moved to November in 2015.
Having a week designated to corporate compliance and ethics allows compliance and ethics (C&E) professionals to focus on the culture of compliance and not just the rules and regulations. Throughout the years, the core principles of Corporate Compliance & Ethics Week have remained focused on three areas: awareness, recognition, and reinforcement.
Awareness
Compliance and ethics professionals can create awareness about their programs by:
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Announcing Corporate Compliance & Ethics Week to all employees through email and company newsletters, social media, and websites;
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Scheduling activities throughout the week for employee participation;
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Communicating the differences between compliance and ethics;
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Publishing a Q&A with the organization’s C&E officer;
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Sending the organization’s employees a photo directory and contact information for the company’s C&E team;
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Launching annual compliance training in conjunction with Corporate Compliance & Ethics Week;
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Hosting live presentations;
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Hosting “Coffee with Compliance” or a meet and greet where employees can get to know members of the compliance and ethics team and ask C&E questions;
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Distributing the seven elements of compliance and highlighting why they are important;
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Reminding employees that each individual plays an integral role in ensuring the organization is compliant and ethical;
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Spotlighting the organization’s hotline number and web-reporting capability, if available, with new posters, printed and electronic banners, and table tents;
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Reminding all employees that they are encouraged to report any C&E concerns to the organization’s hotline;
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Rolling out a new communications campaign for Corporate Compliance & Ethics and educating the organization’s employees about all the ways the C&E team shares information with them about the company’s C&E program;
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Distributing daily compliance tips that culminate in a test with a chance to be entered into a drawing for a prize;
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Distributing a quiz to all employees testing them on important information they should know about the organization’s compliance program;
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Sending out daily inspirational C&E quotes to all employees;
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Inviting a C&E expert to give a keynote address to the company’s employees about the importance of C&E;
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Updating employees on current regulatory focus areas of the Office of Inspector General and U.S. Department of Justice;
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Hosting a scavenger hunt where employees are sent on a search for various C&E–related items, such as the compliance officer’s photo, evidence that the company’s hotline poster is visible in public areas, the location of the compliance policies and code of conduct, and a copy of the notice of privacy practices; and
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Asking employees to be the eyes and ears of the compliance and ethics team by searching the organization for potential Health Insurance Portability and Accountability Act (HIPAA) violations or compliance issues and reporting any findings to the compliance department for further investigation.
Recognition
Corporate Compliance & Ethics Week can bring recognition to an organization’s compliance and ethics program or recognize others for compliance wins by:
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Interviewing or presenting feature stories focused on C&E with the organization’s board chair, CEO, members of senior leadership, and compliance staff distributed via company blogs, live or recorded broadcasts, podcasts, newsletters, and social media (e.g., LinkedIn, Facebook, and Twitter);
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Distributing daily “Did You Know?” compliance facts and/or tips to all employees;
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Highlighting how compliance has prevented risk to the organization;
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Honoring employees who are compliance champions; and
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Recognizing employees for their compliance efforts at an annual awards ceremony.
Reinforcement
Compliance and ethics professionals also can use Compliance & Ethics Week as an opportunity to reinforce the culture of C&E at all levels of the organization by:
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Bringing together members of the board, senior leadership, middle management, and frontline staff to publicly demonstrate their commitment to compliance and ethics;
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Having all employees sign an annual attestation supporting their commitment to C&E;
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Distributing the organization’s code of conduct to all employees and engaging them to sign a statement that they will abide by it;
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Asking employees to sign a Compliance & Ethics Week banner in the organization’s lobby or other public area to show their commitment to doing the right thing;
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Creating a wall in the organization’s lobby or a highly traveled area where employees can write what compliance and ethics means to them; and
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Reminding employees about the organization’s intolerance for retaliation or retribution for reporting alleged compliance issues in good faith and that the organization has a nonretaliation policy.