The Federal Sentencing Guidelines for Organizations (FSGO) pioneered the seven hallmarks to define what an effective compliance program should look like. Regulators from across industries embrace these hallmarks as a foundation and agree they play a pivotal role in defining compliance. Regulators also agree that the backbone of an effective compliance program – the thread that links the hallmarks together – is an effective policy management strategy.
While calling it policy management makes a complex field seem simple, true policy management isn’t just about policies and procedures. Sure, policies and procedures must exist, but successful policies are born from an effective compliance program that touches all aspects of an organization. An effective policy management program threads through all seven of the hallmarks: written policies and procedures, program oversight, ethical due care, training and communications, monitoring and effectiveness, enforcement and internal investigations and remediation.
Policy management must encompass oversight from the top, while simultaneously responding to the needs of employees by taking a bottom-up approach. A true policy management program must monitor its own effectiveness by pinpointing exactly what went wrong, where and how.
Without this information, it’s practically impossible to review and change your policies and remediate behavior. If leadership doesn’t have insight into employee attestation, understanding based on exams or agreement to adhere to policies, enforcing rules and conducting internal investigations is much more difficult. Not to mention, having solid policies and procedures in place is critical to effectively communicate the requirements of your compliance program to the various stakeholders in your organization.
Many people try to manage these moving parts on their own, arguing that they don’t need a software solution to do this for them. However, if you look at the level of granular details regulators ask for, self-created systems simply aren’t effective. And you can no longer get away without taking any action. To proactively protect your organization, your employees and ultimately yourself from compliance breaches, you must act now to create an effective program.
Why should you use technology to help you accomplish this goal? Aside from mitigating risk, which, let’s face it, is pretty much the reason you have a compliance program to begin with, what are the benefits of shelling out for a software solution? How can the right technology help increase the effectiveness of your compliance program?
The right policy management software, such as the PolicyHub solution, provides three major benefits to your overall compliance program. It helps to enforce, automate and evidence your program.
Enforcement is not only a key pillar of an effective compliance program, it’s also a pivotal spoke on the best practice wheel for a policy lifecycle. A policy management solution helps you enforce your tone from the top compliance as well as your adherence to the other hallmarks.
The right software provides program oversight into the granular details of how employees understand policies, where knowledge gaps may lie and who exactly is struggling to understand and adhere to a specific policy. With these insights, enforcement becomes easier because leadership has the information they need to enforce a program effectively and efficiently – without wasting anyone’s valuable time.
PolicyHub, for instance, allows you to follow up with any struggling employees, review your current strategy, provide remedial training and clarification as necessary and enforce ethical behavior as needed.
According to a case study with international reinsurance company Transatlantic Re, they use PolicyHub not only as a communication channel, but because of the essential compliance information it provides to senior management and auditors.
“Transatlantic Re can demonstrate a clear record of which staff have received, read and understood each policy, when they agreed to them and those who have not,” the case study states.
In other words, knowing whether or not an employee read and understood a policy is no longer a question, which makes enforcing compliance an easier problem to solve.
Imagine if you had to use a document management system to create and edit policies, try to track files to ensure your version is the most recent and accurate, try to track who received what policy through email and manually track that information in a spreadsheet. Now imagine you had to send written tests to everyone and grade them by hand. Maybe you don’t have to imagine this, maybe it’s your life right now.
In this scenario, you have no way of knowing if anyone actually reads a policy, much less if they agree to follow it. Running a report with this ‘system’ would also be a total nightmare, if it were possible at all.
Now imagine if you could automate all those processes. If you could just set a few workflows, edit a policy and turn it on. If it could automatically go to the right people at the right time in the right language. If it could automatically require people to attest that they read a policy and agree to adhere to it. Imagine if you could automatically trigger a test to assess the employee’s knowledge of that policy and alert you if an employee failed this test. If you could also automatically send periodic surveys to ensure employees continue to comply to these policies. And if you could set reminders to review your policies in a few years, as regulations change.
These are the exact benefits offered by an effective policy management software solution. A solution like PolicyHub streamlines and automates key compliance business processes so your talented team can focus their attention on more important tasks. With everything automated, including your reports to regulators, you can rest easy, knowing your software has your back.
According to a Mitratech client who is part of the world’s largest provider of food and beverage services for travelers, PolicyHub provides the automation and consistency their international company needs to maintain an effective compliance program. For a large organization, trying to manage training and communicating policies and procedures by hand to employees is simply out of the question.
For this client, PolicyHub established a structured and repeatable process for them to create, update, review and capture deviations for all policies and procedures throughout the company. They can now automatically distribute the right policies to the right employees at the right point of the globe at the right time in the right language.
In today’s regulatory environment, the simple truth is you have to create an audit trail you can easily report on. You have to effectively deliver written policies and procedures, train and communicate those policies to your employees and prove yourself to regulators. And you have to do all this in a way that makes good business sense.
With ad hoc systems, running reports for regulators can take several days, if you can find the information you need to run reports at all. Without a single source of truth for your policy management information, trying to gather everything into one place during a regulatory time crunch can cause chaos across your organization.
With an automated policy management system in place, these reports no longer take days, they take minutes. With a few clicks, you have all the insights into your data you would need to drive informed decisions, report to leadership and most importantly, prove your compliance to regulators. And all the information’s in one easy-to-find place.
“PolicyHub gives us a truly flexible and effective solution,” Vincent Eng, AVP Assistant General Counsel at TransRe states. “Firstly for communicating policies and ensuring response, but more importantly it delivers the compliance reporting and assurance we need to satisfy internal audit, external regulators and the board of directors.”
Interested in finding out how our policy management solution can improve the effectiveness of your compliance function? Connect with us today.