From Policy to Behavioral Change: 4 How-Tos from ex-AIG CCO


“Policies are not enough,” said Suzanne Rich Folsom, former Chief Compliance Officer for AIG, speaking at the recent Dow Jones Global Compliance Symposium .

Policies are only the very first step in an organizational culture that is truly compliant with regulatory requirements. If you want to protect your company, here are four insightful how-tos from Suzanne Rich Folsom and other @dj_gcs speakers to move your policies from paper documents to meaningful behavioral change:

1. Responsibility Framework

  • Identify all those policies that have been created to ensure compliant and ethical behavior across the spectrum of your organization, whether it is national or global.
  • Identify who is responsible for what piece of the puzzle. By assigning individuals, you reinforce personal responsibility and start creating connections and relationships between people who can reinforce the policy goal and intent.

2. Enumerated Monitoring Program

  • State in advance and make available to all how and when you will monitor policy compliance. Have summaries of the practices you use and follow with detail for those who want to dig in.
  • Locate your detailed monitoring program all in one place. Make it easy to find and reduce the idea that there are only “specialists” responsible for compliance. Get everyone on board.
  • Openness shows good faith in employees, which encourages personal responsibility at every job level.
  • Describe why specific time frames are chosen, e.g. why quarterly vs. monthly. This aligns with openness and sharing details, and encourages everyone to pull the oars in the same direction at the same time. You will get farther this way.

3. Tone at the Middle

  • The tone set by leaders matters. That includes directors and managers, not only the CEO.
  • Show that you LIVE the tone from the top. Compliance policies and how to follow them should be topics included in organizational meetings, in company messages, and leaders at every level should support compliance activities (reports, audits, etc.).
  • Talk about the walk. Get leaders — team, midlevel, executives — to share anecdotes of how they think through compliance issues and get input to make sure they are doing the right things.

4. Strong Regulatory Relationships

  • Know and be known (regulators are people, too). If you are committed to policies that work, be willing to put it out there with the regulatory bodies that oversee your organization. If you wait to share your commitment to compliance and strengthening your culture until there are issues brewing, it will be too late.
  • The wheel does not stop turning. Regulations are amended all the time, so being compliant means reviewing your policies with each change. It is a continuous process.
  • Review, plan, then act. Your organization can only be successful for the long-term if you take action to execute plans that reinforce compliance. Implement your plan and follow up, because your organization’s success depends on being compliant.

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3 responses to “From Policy to Behavioral Change: 4 How-Tos from ex-AIG CCO

  1. Pingback: 5 Things You Didn’t Know About Off-Label Sales Compliance | Good Promotional Practices

  2. Pingback: What’s your top tip for off-label sales compliance? | pharmaphorum

  3. Pingback: Live Monitoring of Speaker Programs: Expert How-Tos | Good Promotional Practices

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