Jim writes the monthly business ethics columns for the Association of Corporate Counsel Docket magazine and the Rochester Business Journal. Start by engaging key stakeholders, including internal stakeholders, on the value/why questions, what success will look like and what metrics will help you understand your progress towards success. The whole idea of attempting to manage compliance and ethics risks by supplementing existing corporate structures already created for this purpose with a small group of compliance/ethics professionals is still relatively new. Once you have developed a reliable gauge that your management team has confidence in, encourage your management team to use it to set performance targets in a manner that would hold directors, officers and employees accountable for achieving them. Weâre not living in Victorian times anymore. 18 Essential Metrics to Measure Your Digital Marketing. When ethics are discussed, probably one of the last things to come to mind is measuring them, particularly in numeric terms. However, I think it is fair to say that those ethics and compliance offices that have successfully found a way to demonstrate their worth are likely to weather the current economic storm better than those who are merely reporting ethics line call volumes and training completion rates to their management teams. These metrics also provide insights into compliance effectiveness. Set Goals and Evaluate Performance. Here are the main reasons why they are extremely using these methods: 1. If we are unable to demonstrate to our respective organizations that our efforts are materially reducing costs or compliance/ethics risks, then itâs just a matter of time before compliance offices are shut down or consolidated into more traditional corporate functions like the Law Department, Accounting Department or Human Resources. Employees with strong integrity recognize the importance of completing daily tasks and producing their best work, while those with poor integrity might try to skate by doing the bare minimum. Although our fellow conferees had many other sessions that they could attend, by the time we started every seat was taken and there were people standing along the walls and a couple of ranks deep in the back of the room, with some listening from the open doorway. In addition, organizations should have processes for receiving and resolving broader issues, including consumer complaints. Efficient compliance can address an organizationâs many regulatory mandates through a common set of controls that may require new automated, enterprise-wide controls to replace multiple or compensating controls within business units. In addition, changing culture in organizations is very difficult and almost always takes years to achieve, even in the best of circumstances, and significant, sustained effort to maintain. While there are no universally accepted definitions of what makes a compliance program effective, and there is no one metric for evaluating effectiveness, the pillars of an effective compliance program are sound design and execution, timely and proactive responses to compliance issues, and readiness for regulatory change. Change is a constant in accounting. Lots of it. Check your email for next steps. However, these may not be the most useful metrics given an organizationâs risks and strategic goals. Compliance leaders across industries are focused on assessing and enhancing their compliance effectiveness in response to regulatory requirements and expectations. In recent updates to the indices, Johnson & Johnson and Vodafone were 20 Questions to Ask When Prioritizing Your Policy Development Efforts, 4 Steps for Risk-Based Back-to-Work Planning, From Compliance to Risk Management to Better Performance. Remote Compliance: Managing InfoSec Audits from a Distance, 5 Steps to Implement a Sanctions Compliance Program, Paying the Price: Compliance Challenges in 2020 and Beyond, Aligning your Compliance Program to the Latest DOJ Guidance, Retiring Enterprise Applications: 4 Key Considerations. In addition to effectiveness, organizations with more mature compliance efforts often find that the next step in their compliance journeyâand a key to realizing a return on their investmentâis making compliance more efficient and sustainable. Jim is a National Association of Corporate Directors Fellow, a member of the International Association of Independent Corporate Monitors and serves on the Board of Directors of the Rochester Chapter of Conscious Capitalism as the Boardâs Secretary and Chair of the Governance and Nomination Committee. To address these issues, a list of recommended metrics includes: The next set of API metrics are business performance metrics. After ethical performance measures are in place, the business owner sets goals for improving the companyâs ethical performance. Transformation. Activation: what % have a âhappyâ initial experience? Find an easy way to present your metrics to them that is easy to understand at a glance. Rightly or wrongly,some would argue that a quantitative approach to measuring ethical behavior in a corporate entity is somehow alien to ethics and moral deliberation. The most basic set of API metrics is operational. Without such a correlation, you will continue to cast around in the darkness, never knowing whether you are making progress toward your intended destination. Such metrics, though, favour short-term wins, shareholder demands and performance bonuses, rather than longer-term growth. Effective ethics programs will incorporate many if not all of the 11 elements listed above and will be measured by at least several of the types of metrics reported above. Karola Karlson. Productivity depends on the time you spend on tasks and other in-house activities. Sponsored by: Convercent; Every organization should integrate information, processes, and systems to deliver metrics that support the ability of the business to achieve objectives while addressing uncertainty and acting with integrity. Step-by-Step Guide:Â 8 Steps to an Effective Compliance Programme. What metrics do you use in your organization to measure the success of your compliance initiatives? They typically also consider the Committee of Sponsoring Organizationsâ (COSO) internal controls framework and guidance and measure their program against the seven topics set forth in the U.S. Federal Sentencing Guidelines. 28. Decide what specific metrics you will measure each year and then analyze data for trends. While there is room for improvement, it is heartening that ethics and compliance programs are moving beyond the check-the-box approach to a broader systems approach. To track and increase productivity managers use metrics identifying and prioritizing emerging issues. Donât confuse process and activities metrics with outcome metrics. They measure API performance, such as the number of APIs, the number of API calls, CPU or memory usage. #own-it â Have pride in â¦ It is important to gather data in a manner to determine whether there is a cause and effect relationship between your compliance and ethics program and key outcomes. As we reviewed everyoneâs key benchmarks, one question guided the discussion: 26. Philosophers disagree about what constitutes ethical standards, and there is more than one framework in which to approach the concept of ethics. There are over 250 global and local ethical indices schemes, with FTSE4Good and the Dow Jones Sustainability Index (DJSI) two most well known ethical investment indices for UK companies. This can be especially important for decentralized organizations and organizations that operate under multiple regulatory jurisdictions and face growing challenges in tracking and managing regulatory changes. Measure or Die! “Measuring compliance and ethics performance at our firms is vital to our success as a profession.”. #CSR Impact metrics can waste time, money and goodwill. Jim has extensive experience in implementing world-class compliance and ethics programs sufficiently robust to withstand U.S. Department of Justice scrutiny. The time at which we ask employees to attest to a policy may determine if the standards in that policy are followed. Illustration filed in Compliance, Ethics. 6 Ways to Avoid Conflicts of Interest During the Holidays, Definitive Guide to Compliance Program Assessment, 8 Steps to an Effective Compliance Programme. Business metrics. In the event you donât already have a robust and meaningful set of compliance and ethics key performance indicators (âKPIâsâ) at your company, here are a couple of things you might consider doing to remedy the situation: Just because youâve got all of the elements of the US Organizational Sentencing Guidelinesâ seven elements of and effective compliance and ethics program and have done thousands of hours of compliance training does not mean youâve succeeded in improving your firmâs compliance and ethics performance. App Store User Reviews. Examples of such forward-looking metrics might include a âclick rateâ that measures the number of employees who have read a particular policy, or tracking minor employee misconduct as an indicator of potentially more serious future misconduct. At Hubstaff, in addition to using our own productivity tracker, we measure the success of our team based on our core values: 1. While every KPI has value, call centers need to focus on a limited number of these metrics to ensure they prioritize and make effective decisions. This slide contained the simple statement: âMeasure or Die.â I noted at the time that this blunt pronouncement may seem a bit hyperbolic, but that itâs not far from the mark. You need an independent set of Outcome metrics to show whether all your efforts are yielding results. Readiness for regulatory change requires organizations to both anticipate regulatory changes and respond quickly to comply. In response, compliance leaders are increasingly pursuing multidimensional metrics that link operational performance with compliance as well as metrics that can provide a deeper understanding of the organizationâs compliance effectiveness. There can be other metrics which are relevant to your line of business which should be tracked along with the metrics mentioned above. Sound design and execution is the foundation of effective compliance. Unlike many other departments, call centers have metrics available to measure results up to the minute and second. 2. Of course, no function in a company is immune from budget cuts and this is doubly true of those that are not directly related to income generation. Metrics to measure: Retain more clients, % realization per client, improvements in chargeable hours per client. Have a conversation with your management team to see what data they would find useful in allocating limited resources to better manage compliance and ethics risks. Jim spent the first 17 years of his career as a criminal and civil litigator and Senior Corporate Counsel before becoming Crompton Corporationâs first Vice President, Business Ethics and Compliance in 2003. - Using Metrics to Measure Compliance Performance was written by CCI featured author Jim Nortz, the Compliance Director at Bausch & Lomb. Illustration â Integrated Compliance & Ethics Metrics. Retention: do they come back over time? In a business setting, an employee's integrity can affect her work ethic. Jim Nortz is Founder & President of Axiom Compliance & Ethics Solutions LLC, a firm dedicated to driving ethical excellence by helping organizations implement effective compliance and ethics programs. User Satisfaction Metrics. 2. User Feedback. App Store Ratings. Each of us provided what we characterized as ârapid fireâ 10- to 15-minute presentations providing our thoughts on how to best measure a companyâs compliance and ethics performance. Regulators in certain industries have developed industry-specific guidance. Chat with a solutions expert to learn how you can take your compliance program to the next level of maturity. Multidimensional metrics, for example, can enable an organization to better understand the root causes of issues related to retention, engagement, and attitude; the time needed to close audit issues and the number of repeat issues; and client satisfaction or complaints at the business unit level. Traditional metrics, such as net present value and internal rate of return, help finance to communicate with stakeholders. Depending on where you are in your marketing journey, digital marketing is either a voodoo-like superstition or a teachable science anyone can master. Revenue: can you â¦ 30. Multidimensional metrics, for example, can enable an organization to better understand the root causes of issues related to retention, engagement, and attitude; the time needed to close audit issues and the number of repeat issues; and client satisfaction or complaints at the business unit level. A critical part of this response is the ability to implement a sustainable process to self-identify and self-report to regulators potential or alleged misconduct in advance of regulatory scrutiny. Given staffing pressures and recent high attrition rates, embedding sustainable processes is increasing in importance. But how is âethicsâ measured? A measure is a quantifiable expression of performance collected during the execution of activities. Identifying and measuring the ethical standards and personal integrity of others is difficult. I attempted to reflect this sentiment in the last slide in my presentation. Learn to measure and manage the meaningful. How do you measure ethics in business? In addition, compliance leaders in organizations with more mature programs are also attentive to the need to improve the sustainability and efficiency of their programs. During your employeeâs performance review, ask him to demonstrate how he completes job tasks in an efficient and cost-effective manner, and how this helps your company achieve its competitive edge. How to Measure Work Ethics & Integrity. Deliberate time management is what developers have often problems with. Everything about your business, one click away. Using a variety of metrics also can help CCOs determine the ethics and compliance programâs future budget. Proposed by Gabor Papp in 2017, RARRA is almost identical to AARRR except it re-prioritized âRetentionâ over âAcquisitionâ: 1. Furthermore, compliance leaders recognize the limits of one-dimensional statistics, such as feedback from customers and regulators or decreasing fines. Why do development teams use metrics to measure quality? The lessons here include more than just having a strong policy and procedure management program, but also pairing it with an effective compliance training program that inculcates strong processes that can withstand pressure and not sacrifice core values. ethical behavior in the workplace as a whole is hard to measure and an attempt to quantify it should go through the use of combined Key Performance Indicators (KPI). In addition, certain metrics gleaned from employee surveys, cultural assessments, or focus groups can demonstrate how the compliance program is deployed within an organization and highlight the soundness of its design and execution. . Innovation is a tricky thing to measure because it is difficult to separate from business-as-usual activities such as improvement.The goal of innovation is to create new techniques and products that are an order of magnitude better than the closest competition. They can use metrics to communicate an issue, report a progress of a project, and improve their workflow. Additionally, sustainable compliance requires compliance leaders to demonstrate effectiveness throughout the supervisory cycle as well as repeatable processes for an external consultant or audit assessment. The breadth of KPI measures led to a key discussion on how to turn these metrics into early warning signs in order to better establish a predictive, low cost ethics and compliance program. While many compliance leaders are beginning to realize the value of their compliance investment through this focus on effectiveness, they often struggle with how to evaluate it. Being able to demonstrate proficiency after taking a course can be the key to providing employees with those training experiences that actually work as indicated by performance metrics. by Jack Torrance. And, when metrics are used to identify problems and make improvements to the learning experience, youâll be able to increase the value of training for both learners and the business. 5. Nearly one-third of the nearly 200 companies surveyed do not measure the effectiveness of their compliance programs. Previously, Jim served on the Board of Directors for the Ethics and Compliance Officers Association and the Board of the Rochester Area Business Ethics Foundation. This includes revisions to its internal infrastructure and approaches. The strategic moments at which we encourage honesty can directly impact the immediate decision making choices that follow. â¢ Develop metrics to measure program effectiveness, providing impactful analysis to the business and appropriately influencing outcomes â¢ Detect, investigate and accurately report on potentially suspicious activity, both today and in the future, to the satisfaction of the regulators Enterprise Compliance and Ethics: Net Promoter Score (NPS) 27. FTSE firms have been panned for not reporting their ethical performance - but doing good is difficult to define. To assess design and execution, many compliance leaders look at their key risk indicators (KRIs) year over year or at surveys of targeted employees. Monitoring and communicating compliance programsâ effectiveness is crucial, but the metrics some companies use may be too basic and possibly inadequate, according to a new report from Deloitte and Compliance Week. Further, leaders are seeking data and analytics and other forward-looking predictive measures, as well as utilizing behavioral science indicia, to assess compliance trends and to enhance their understanding of emerging risks and potential misconduct. Timing can be everything, so letâs discuss how to make the most of our time. They provide an index for investors as to what can be considered an âethical investmentâ. Support Turnaround time. Karola has got years of experience in growth marketing and working with SaaS startups. 29. While misconduct, gaps, and other issues can still occur regardless of the strength of an organizationâs compliance program, how an organization responds to a problem or crisis reflects its compliance effectiveness. Editor’s note: This article was contributed to Corporate Compliance Insights by Jim Nortz. The golf course could measure the actual reduction in water usage. Choose which work from home metrics you measure based on whatâs most important to your company. This includes ensuring that they have a strong compliance culture embedded throughout the organization and that they are able to demonstrate to their boards and regulators that they understand and can manage their compliance risks. But how, exactly, does one define an ethical business practice and, more to the point, how does one measure ethical behavior? Jim is a nationally recognized expert and thought leader in the field of business ethics and compliance with over a decade of experience serving multinational petrochemical, staffing, business process outsourcing, pharmaceutical and medical device corporations. For example, the ethical behavior of â¦ 4. Using technology is one way to measure the impact of a learning experience. Thank you for subscribing! Assessments, for example, can also provide insights on cultural issues across the enterprise or on compliance bypasses that would not necessarily be caught through the other metrics. Determining which metrics your employees can affect also contributes to developing employee morale, loyalty and job satisfaction. Managing employee compliance with policies and â¦ When it comes to ethics and compliance messages being heard, absorbed and acted on, timing is everything. Many people assume that you have to choose one set of metrics over the other. If you are a compliance/ethics officer in a company with well run functions (legal, HR, regulatory, etc…) your firmâs compliance and ethics performance is probably already pretty good. What metrics do you wish your organization had in place for such measurement. 3. Since most managers will give you a blank stare when you ask them what compliance and ethics metrics theyâd like to see, be prepared to provide them with a menu of options and help them understand how they could be put to use. By taking some of these ideas into account and developing meaningful compliance and ethics KPIâs, my hope is our profession will not only survive but thrive in the long-run, and live up to its potential of helping corporations navigate in increasingly complex and hazardous regulatory environments. VComplyâs dashboard provides relevant insights of the level of compliance. Jim is a frequent guest lecturer at the University of Rochesterâs Simon School of Business, RITâs Saunders School of Business, St. John Fisher College, Nazareth College and other law schools, universities and organizations around the country. HOW DO YOU MEASURE EFFECTIVENESS? Todayâs increasing emphasis on metrics in sustainability policy and management presents an interesting challenge for ethics. Make sure your management understands these realities and takes them into account in evaluating the compliance and ethics KPIâs and in setting goals. Research has found that culture, leadership, and values-based ethics and compliance programs increase employee reporting of misconduct and decrease retaliation. A combination of those hard metrics and soft ones would likely provide the best overall measure of a program's success. Originally appeared in KPMGâs âThe Compliance Investmentâ. Demonstrating the effectiveness of your training is made much easier by using appropriate training metrics. CONCLUSION WHY COMPLIANCE INSIGHTS MATTER Federal Sentencing Guidelines for Organizations (FSGO) lists measuring effectiveness, that is evaluating periodically the effectiveness of the organizationâs compliance and ethics program. Referral: do they like it enough to tell their friends? To go from 98% to 99% compliance may require as much focus, discipline and energy as achieving the first 98%. But you're forgetting to measure what matters most to overall success: ethical behavior. While these metrics provide some insight, they do not generally enhance an organizationâs awareness of its actual compliance effectiveness. Share your thoughts in the comments section! Many rely on internal metrics for insight into the effectiveness of their programs, including year-over-year improvement and how well they are filling self-identified compliance gaps and inefficiencies, as well as through an external analysis against peers. Be strategic. Step-by-Step Guide: 8 Steps to an Effective Compliance Programme, Multidimensional metrics, for example, can enable an organization to better understand the root causes of issues related to retention, engagement, and attitude; the time needed to close audit issues and the number of repeat issues; and client satisfaction or complaints at the business unit level.Â. METRICS TO GATHER HOW TO SET COMPLIANCE KPIS TS WHAT TO MEASURE? Although Iâd like to think otherwise, the reason such a crowd gathered was not because of our collective star power; it was because there is a widespread recognition by compliance and ethics officers that measuring compliance and ethics performance at our firms is vital to our success as a profession. The ability to adapt and prepare for the future is an essential component of success. A couple weeks after the dust has settled in the arrest of the University of Utah nurse for upholding hospital policy, itâs time to investigate to see what ethics and compliance officers can learn. Here are three ways to measure training effectiveness: A metric is a specific measurement or calculation associated with performance. Metrics are repeated measures that are applied as references for assessing variance as compared to a defined target. Your management team is already suffering from KPI overload. It has been updated for clarity.Â, A few years ago I had the pleasure of participating with Scott Mitchell, Chairman and CEO of the Open Compliance and Ethics Group, and Charles Ruthford, a compliance and ethics officer at Boeing Corporation, in conducting a training session at an Ethics and Compliance Officers Association Conference.The session was entitled: âCounting on Metrics: Developing meaningful E&C program data to satisfy a âShow meâ CEO.â. Operational metrics give an indication of the operational stability of an API platform. You can measure yourself to death. Since then, Jim has served as a compliance officer at Crompton and for five other multinational corporations, the most recent of which was as Chief Compliance Officer at Carestream Health. LMS Metrics to Measure Training Effectiveness. Innovation metrics are techniques for measuring the innovation efforts of an organization. Try for free . These presentations were followed by about 45 minutes of open Q&A and discussion about the topic. Which business metrics do you measure and what are the best tools for doing it? A business may think it has the best call center, but it won't know for sure until it measures and reports the proper KPIs and metrics. Additionally, surveys can measure the strength of internal controls, identify best practices, and detect new risk areas. Interested in how to measure CSR?See this page for a guide to our coverage.. 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