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Pauline Blondet, August 23 2024

An Ethics & Compliance health check for your Business Units 🩺

I propose to move from “having a general idea” to collecting regular and consistent data to prioritize our actions. Too much work? Too many surveys? It does not need to be that way. In today’s blog post, we propose a simple yet effective data driven approach to monitor key health indicators for all of your Business Units worldwide.

We often spend way too much time defining programs, and not enough time confirming that all our initiatives are effectively embedded within our group. And then sometimes we are surprised to see that this dawn raid process never made it to our South Korean office receptionists.

It’s hard. You sit in Switzerland and have to hope that the framework you put in place is impacting your Korean entity effectively. E&C Teams often feel lonely. Have you ever visited a market to learn that a key minimum requirement of the E&C Program (say the availability of the hotline posters on all sites) was far from being met? It’s nothing new, and our work consists in ensuring that we consistently and relentlessly deploy our requirements in every single operating entity worldwide. Grit is the name of the game here.

And then of course, we need to check and confirm that this is still the case, on a regular basis.

That’s where our Ambassadors and key contacts play a key role: they are our relays in each local market, the ones who help us make our voices heard and our initiatives a reality on the ground. Check out my article Real Skills for E&C Professionals: Creating a Successful Network of E&C Ambassadors ✨ to find out more tips on how to set up and maintain an effective network.

Once we have this network in place, it is much easier to deploy our initiatives and make sure they are well documented. As to ensuring they survive through time, it is very much about making our initiatives recurring. 

My colleagues should help me confirm on a regular basis that:

But how can we measure what we do, what they do and our overall health on a given topic? There’s of course many many ways to do this. Today, I would like to propose one simple and effective way to start creating systematic data collection, Business Unit by Business Unit. 

This method does not require complex projects with data scientists or integration with your ERP systems : many of us don’t have the resources or the time for that. If you do, it's wonderful, go for it. What I propose today is to start small and consistent, and then build on it as you grow more mature with this process.

Why do we want to collect data Business Unit by Business Unit?

Our goal is to build a set of indicators that can easily be deployed toward all of our Business Units. Such a deployment allows to:

So, we know our scope: all the Business Units of our group. It does not mean we will want to send our assessment to 380 entities in one go (depends on your tooling and resources, of course), we can work with several waves. But the idea is to get a consistent regular data collection going across the group.

One Questionnaire per Topic

As for the reporting, we can see on our side that many of our customers enjoy using a dedicated Health Check Questionnaire per Topic (i.e. one for Anti corruption, one for Antitrust, one for Modern Slavery, one for Data Protection etc.) in which a few important and specific KPIs are asked about. 

This does not sound like a lot, but if you had one Questionnaire per Topic including 10 questions, and 5 Topics you actually want to focus on, this is already 50 questions. Deployed across 30 Business Units, this would lead to a live “health check” based on 1,500 data points (50x30). There you go on consistent data collection!

If you prefer to start small and build on it progressively, don't assess all your Topics at once, rather start with a general Ethics Health Check, or a minimum requirements check (asking questions such as “Is the hotline available?” “Are the risky third parties checked” etc.), and then add dedicated health questions related to more specific Topics as you grow more mature.

On which you get real time data 

Ideally, you want to get real time data from your colleagues (this requires tooling). If you can’t,  just get this data at a recurrence that works for you: quarterly seems about right. 

You may tell me: that’s quite a lot of work to coordinate and collect all this data. I agree. This is why, at Upright Solutions, we have created a pragmatic tool to do just that and automate the collecting, compiling and aggregating of this data at scale in all the Business Units of your Group. This allows the team in the Head Office to get real-time insights, rank the Business Units by maturity and prioritize their future measures and actions. It’s set-up in a matters of days and you get perfectly compiled and documented results. Check us out if you're interested!


Which data points should we collect to run our Health Check?

This of course depends on the information you’d like to get. Below you’ll find a few ideas on questions for you to adjust further for every single Topic you are in charge of (one questionnaire for ABC, one for Antitrust, one for Data Protection and so on). 

Feel free to attach a color code and/or a score to every answer in order to quickly spot the maturity or health of the Business Unit who is responding. This is also a great place to collect all the supporting evidence, hence documenting your program in real time. Questions apply to the relevant reporting period.

Also, simplicity wins, and collecting data could look like this (this is in no way exhaustive, just ideas for inspiration, and please make sure to adjust the questions, proposed answers, add and remove as you see fit before deploying, you know the drill). This will very much need to be adjusted depending on your maturity. If you're still working to get your teams to brief leadership once a quarter on a given topic, this should be a good score. The colors listed are ways to easily spot what is a green score, from what is a red score, of course, adjust there as well based on what you consider good at your current maturity level.

As mentioned, the answer options given and the colour you attribute to them should match your roadmap and plan. For example, you may have as an objective to have a minimum of 3 tone at the top communications on ABC every 6 months. Or you have as an objective that all sales team should be trained on the topic of ABC every 6 months, this should inform how you draft your questions and the answers you propose.

These Questionnaires could be set-up, rolled out to all the Business Units of your group, monitored continuously by the Head Office, and reported to top management on a regular basis. 

The benefits of a regular health check for you and for your Business Units

Once you set up a regular health check, you can now real-time track the maturity of all of your Business Units and see where most effort from you and your team are required.  You’ll also be able to set a measurable bar for progress, and get people working on getting a better health score progressively.

You’ll also be able to compare data, quarter by quarter, and identify any drop in performance that may occur along the way. It’s very simple if you use the colour codes: the BUs that require the most of your team's attention are mostly red, while the "well performing" BUs are mostly green.

Of course, you will be able to consistently report to your management on those indicators, and this will be a great data driven way to prioritize your action, allocate resources and keep improving etc.

If you’d like to run consistent health checks across all your Business Units but are not sure about the whole coordinate and result analysis part, because you’re already swamped: we can absolutely make this exercise a breeze with our Ethical software, and you could be up and running in just a few days. Contact us if you’re interested.

I hope the above few points are a helpful way to get started on measuring the health of your Business Units and prioritize your actions to get your group to consistently improve on their E&C maturity, it does not need to be super complicated !

Follow-us on Upright Solutions on Linkedin for more inspiration.

Love from Copenhagen 💜



Written by

Pauline Blondet

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