Rebuilding a Corporate Mad House. How Strong is Your Compliance Mechanisms

Compliance Blue Marker
When restructuring, people must be laid off.  For me, I hire slowly and fire swiftly. There should be no job security. The worst customer service and work ethics comes from institutions that pride themselves of ensuring job security (like the Nigerian government agencies at all level). Personally, during on boarding processes for new staff, I make it clear, that no one should fire anyone. The only person that has the right to fire you is you. And that is by incrementally going against our collective accords. Your only guard of your job should be your competency, character and any other reason you were hired and more. But the truth is, you can’t always fire people for doing wrong. So you have to protect them from doing wrong, so you can protect your firm. As a CEO, their has to be a balance between effectiveness and efficiency. So it may cost you more to keep hiring and firing people. Laying off the wrong people for the right people, is key in restructuring. Its importance for their psychology of work to declare that its not business as usual. After that comes definition of new process. But you need a compliance system to avoid a relapse.
Operational documents like job descriptions, intended corporate culture, brand promises and Standard Operating Procedures, even when defined, written down and assigned might still not be followed through except their is a strong compliance mechanism. So you need a compliance system. Everyone’s work they say is nobody’s work, so someone (or a department depending on how big your organization is) has to be held responsible. The same way a marketer is placed on target, and may be fired when that target is not met, is the same way a compliance person has to be put on ground with a target to query, suspend and even fire anyone (from the buttom up, including you, even if you’re the CEO) if not met. 
The compliance manager reserves the right to query and even suspend anyone in the firm, even if the person is above him/her in organizational hierarchy.
One activity that greatly improves the credibility of the compliance  system is effectiveness communications of the rules of the game, the policies, procedure and declaration of possible conequencies in terms of reward and sanctions.  Being assertive and true with promises and threat is important. And then following through with an eagle’s eye view as well as  detailed microscopic lens. This includes the use of unannounced compliance checks. This allow the compliance Manager  to assess what is happening  during a ‘typical’ day, in contrast to the potential artificial environment established for an announced compliance check.
This procedure shall be conducted within the calendar year at random, for everyone,  for each department and store.
They will include
  • Mystery Shopping: Here, someone is hired to walk in like a customer so as to catch the sales force and other relative team members with their guards down.  It can be as petty as snooping through, or strategically, usually, they are either wired or have hidden camera with a checklist of what may be done wrongly as against the SOPS. The role of this is to verify whether the brand’s promises, brand loyalty,  SOPs and Job description are being followed. The mystery shopper can turn up at business premises unannounced to review records, ask to see documents and request access to computer systems.
Take for example, a mystery inspector can pose as couple out to buy a quick dinner at a restaurant . Their purchase is later checked against the restaurant’s end-of-year books to see whether it has been properly accounted for.
  • Credibility Checks: For character flaws and vulnerability to carelessness (from personal online profiles and checks, to ensuring that trade secrets and other privacy and non disclosure documents are intact).
  • Internal mentor ship is key, let the high flyers of your team mentor the rookies and allow him or her rub off on them systematically. It helps in the sustainability of excellence.  its an abstract view on compliance. 
The Compliance Managers are to select those departments who will receive an unannounced check relative to the number of Announced compliance checks planned within the calendar year. This should be done and assigned with utmost secrecy.
An unannounced audit will be scheduled in addition to the regular compliance cycle and can only replace surveillance when it is ensured that all relevant criteria will be checked.
If the department head refuses to cooporate for whatever reason, then this is ground for an immediate implementation of disciplinary action.
In terms of disciplinary actions, there should be a committee on discipline, review of the firms balanced score card and performance measurement. This should be done quarter. But  at the end of every quarter, there is a measurement of each person with grading for rewards and sanctions. The top 25 percent performers are rewarded while the bottom 25 percent are laid off. These are a few of how to create a compliance system that supports your vision and operating procedures.