People-Power Your Compliance ProgramMary-James (Jami) YoungSenior Counsel, Compliance and RegulatoryVectren CorporationOctober 2013mjyoung@vectren.com; maryjamesyoung@gmail.com

Overview• Why “People-Powered” Compliance?• Culture of Compliance• Tone at the Top

• Five Pillars of People-Powered Compliance• Empowerment• Responsibility• Resilience• Integrity• Measures (not metrics, measures)

Criteria• High Impact/Low Cost Program Enhancements• Accessible, Workable Changes and Tweaks• Tangible Results/Positive Outcomes• Applications Beyond compliance enhance the rest of the

business, and the rest of life• Easily communicated, transformative changes• Ripple effects of positive changes

People-Power• What is “people power”?• Why does it matter?• How do we harness/direct it?• How does it interface with “gee whiz” GRC software solutions?• Can it be taught/learned?• How does it start?

Five Pillars• Why Five Pillars?• Foundational to our Compliance Efforts• We “grow our people”• We recruit from within our Company• We receive inquiries from employees who want to join

compliance (!!!!)• We studied Human Factors, Human Performance and Humans

as Heroes……….

Empowerment• Humans as “heroes”• Mindful, present, engaged and thinking through every function,

every day• Spotting issues and potential problems and correcting those

before they manifest• Proactive, not reactive• Aware of and educated in the core mission, and • EMPOWERED TO MAKE GOOD THINGS HAPPEN• Empowered to stop bad things from happening

Responsibility• Personal Responsibility• No one “walks past” a problem• Everyone works together to solve a problem• Everyone proactive in anticipating potential problems and taking

steps to correct those quickly (see Empowerment)• Everyone “owns” the processes and the outcomes• Everyone invests in the success of each of us• When one of succeeds, we all succeed………..

Resilience• Personal Resilience leads to Group Resilience• What is resilience?

• In life• In compliance programs

• Why does resilience matter?• Where does it come from – grown or learned?• How do we foster resilience among our compliance

professionals?• Resilience is picking up the pieces, and putting it back together

BETTER than it was

Integrity• Doing the right thing, every time, even when no one else is

watching what we do• Knowing the right thing to do• Understanding how to model and lead others toward the right

thing to do• Recognizing that the “journey” matters as much as the

“destination”• Building good choices into good actions and good results for a

great compliance program

Measures, Not Just Metrics• Query – how do we measure a culture of compliance, anyway?• Demonstrably robust Culture of Compliance:

• Federal Sentencing Guidelines• Federal (and some state) Regulatory Enforcement Matrices• Tone at the Top – communicated expectation that we do the right

things• No consensus on the “right” measure(s)• Strong consensus that measures not “chill” or inhibit the culture

of compliance

Measures, continued• Two Purposes for our Measures:• Internal diagnostic tool to identify blind spots, compliance risks,

and areas for improvement• Means for providing targeted, anonymous feedback and ideas for

improvement• Methodology:• Seven “open-ended” questions posed in a “facilitated interview

setting”• Responses compiled and assessed and acted upon

Bonus Features: Managing the 3 Cs:Change, Conflicts and Compliance

• Change Management: three elements, always• Logos, Pathos, Ethos or Rider, Elephant, Path

• Conflict Management: five steps to success• Hold your fire, disarm your adversary, change the game, find the

yeses, tap your inner “third force”• Compliance Management: GRC software programs will come

and go, and people are a constant element of any compliance program

Three Things to Remember, Always:

• In Compliance (and in life)….• Context is Key – See the big picture, always

• Understand the pull and tug of external forces• Everyone has a boss – Know your constituencies• Recognize and diffuse those “battles by proxy”

• Everyone Brings their Own Baggage• Acknowledge your baggage • Anticipate the baggage of others• Meet the unspoken needs; success from both perspectives

• Build the Relationships as You Go• Choose your battles• Look for Face-saving opportunities (theirs and yours)• Courtesy is cheap and effective and the right thing to do……

Conclusions• Recognize and understand the key role that people play in any

compliance program • Harness and direct people towards positive contributions to

program and to the larger culture of compliance• Acknowledge successes and leverage those “teachable

moments” to really teach your people (and watch and cheer while they teach others, and the cycle continues……)

Thank you.

Questions? Comments?