Senior Leadership Engagement

March 1, 2024

By Sarah Couture (Principal at Couture Consulting LLC in Indianapolis, IN.)

Originally Posted on: Compliance Cosmos

It is essential that compliance programs engage their organization’s senior leaders. This is not only an expectation from a regulatory perspective, but it is critical to foster compliance program effectiveness.

An organization’s senior leadership is made up of executives who oversee various parts of operations. Frequently referred to as the “C-suite,” they often have titles that include the term “chief” (e.g., chief operating officer (COO)), denoting that they have operational oversight of a function. For an organization to have a culture of compliance and pursue compliant operations, it is crucial that senior leaders be engaged in compliance; they must understand compliance, be “bought-in” to and drive compliance. As with the board of directors, senior leaders determine the “tone at the top” that feeds the culture of compliance. From a practical perspective, a compliance program will struggle to succeed without senior leadership’s engagement. In addition to the pragmatic perspective, there is a regulatory compliance expectation of senior leaders. Government guidance makes it clear that senior leaders have a responsibility to not only ensure the organization has an effective compliance program[1] but also actively promote the “company’s ethical standards,” as well as to convey and disseminate them “in clear and unambiguous terms,” and demonstrate “rigorous adherence by example.”[2] The way that senior leaders make business decisions, lead their teams, communicate, etc., should evidence, both in word and action, their commitment to the compliance program and compliant operations.

While this engagement is vital, it can sometimes be daunting. Compliance officers must focus on communication and connections. Help senior leaders understand their compliance responsibilities through ongoing education and training. If leaders have not been supportive, it may be that they are not aware of the expectations. Consider training content specifically for leadership that outlines their compliance roles and responsibilities and their important part in supporting a culture of compliance. Confirm that the responsibilities are reinforced in job descriptions and performance evaluations.

Pursue intentional relationships with senior leaders and strive to be seen as a helpful peer and thought partner who is approachable, available, and strategic. Ideally, compliance should already be part of the leadership team. Beyond the group interactions, prioritize regular and scheduled one-on-one meetings with senior leaders who oversee specific risk areas. Finally, develop a new leader meet-and-greet process and introduce yourself and the compliance program to help build rapport in early tenure.

1 U.S. Sentencing Commission, “2018 Chapter 8 – Sentencing of Organizations,” Federal Sentencing Guidelines, 2018, https://www.ussc.gov/guidelines/2018-guidelines-manual/2018-chapter-8.

2 U.S. Department of Justice, Criminal Division, Evaluation of Corporate Compliance Programs, updated March 2023, https://www.justice.gov/criminal-fraud/page/file/937501/download.

Copyright 2024 Compliance Today, a publication of the Health Care Compliance Association (HCCA)

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