Compliance is becoming increasingly important for the entire corporate culture. Following the principle of a tone from the top, managers have a special responsibility.
With this in mind, the Alliance for Integrity, together with the German Global Compact Network and the German Institute for Compliance e.V. (DICO e.V.) organised a webinar in early May on the subject of Leadership Compliance.
As theoretical input, attorney Georg Gößwein, independent arbitrator, mediator and managing partner of PLLOB Compliance GmbH, presented challenges and possible solutions that arise from integrating compliance into the corporate culture. With interactive questions, he invited the 100 participants to assess current issues and contribute their own experiences to the discussion. Using recent studies as examples, Gößwein explained that many managers need to be more aware of compliance. Compliance regulations are important, he said, but many companies lack a lively culture.
In the past, fear and firm beliefs were the driving forces for anchoring compliance on the long-term. As a result, many managers nowadays are confronted with a compliance dilemma that needs to be overcome. It helps to enthuse managers for compliance. In order to achieve this, Gößwein suggests assigning specific areas of responsibility with regard to compliance. In the interactive voting, the participants of the webinar were convinced that managers should understand compliance as one of their Tasks. In addition, Competencies and a sense of Responsibility for compliance should also be promoted within the company. With this so-called Management TCR, managers can establish a transparent corporate culture based on integrity. "Compliance must become an integral part of the corporate DNA," emphasised Gößwein.
Afterwards, Regina Pede, Integrity Officer Germany at Vattenfall GmbH and Head of the Working Group Leadership Compliance at DICO e.V., gave insights into corporate practices and shared experiences from her personal everyday work.
In her presentation she underlined the role of managers and compliance officers as ambassadors for integrity. Compliance officers should not act as a controlling authority, but rather support and assist managers in their task of ensuring integrity. Employees primarily follow their manager, not the compliance officer.
It is therefore a compliance task to provide clear guidelines, materials and trainings as well as to offer advice and support.
In this context, middle management in particular is playing an important role. The focus is on the relationship between managers and their employees. Pede explained: "It is not enough to just involve the top management in compliance issues and communications. An effective compliance culture is best practiced in the direct working environment. Superiors have a role model function that they must actively fulfil. This requires an error culture in which infringements can be communicated openly and without fear. By admitting their own mistakes and making them transparent to their employees, supervisors create an environment of trust. It has also been shown that it is best to discuss mistakes openly within the team, so that the whole department can learn from them.
Moreover, Pede emphasised the role of proven compliance measures, such as the integration of compliance issues into messages from top management and the exchange between different departments. The topic of pre-employment screening aroused particular interest among the participants. In addition to demanding a certificate of good conduct, the applicants' understanding of corporate integrity can already be tested within the assessment centre. According to Pede, dialogue and cooperation with the HR department and top management are essential in this context, as such processes are their field of responsibility and cannot be introduced by the compliance department alone.
Based on this, Gößwein presented theoretical approaches for building a corporate culture of integrity. He emphasised that employees need help in difficult decision-making processes. He explained: "Companies must offer their employees sustainable and comprehensible orientation guidelines. Less is often more. A short formula for good compliance, which employees remember at the moment of decision making, prevents infringements. Ideally, the formula should cover all aspects of good compliance and emphasise the role model function of each individual. If employees internalise compliance in this way, it will lead to a change in their attitude. Employees are thus able to make intuitive decisions with integrity.
Finally, Gößwein recommended that management should continuously reflect on the culture of integrity by means of a condensed catalogue of eight questions. Only in this way existing processes can be optimised and possible crisis situations prevented.
Authors: Elena Rittger and Tiam Ghorab