On June 23rd I had the pleasure of co-hosting a webinar with Eric A. Sohn, Director of Business Product for Dow Jones Risk and Compliance. The webinar, “Check Your Baggage. Check Your Expenses: Was Bribery on Your Itinerary?” was a great success, and I received a fantastic follow up question after the webinar that I wanted to be sure made it onto the blog, as I believe many of our current users are struggling with the same issue.
I received an email that asked, “Sending emails to remind travelers of the corporate policies is not as effective as we would like, because people either delete the emails or file them in a folder and do not read them. What we can do to avoid this kind of behavior?”
Getting the attention of employees is always a challenge in any compliance effort. In our Oversight Insights On Demand™ software platform we offer a case management capability that (among other features) can email employees directly about out-of-compliance spending. Our “Oversight” emails have two potential advantages over a “company-wide” email blast.
First the email’s content and subject will be specific to a particular incident – “Your expense report on xx day had this problem” so they know the email is specific to them and not to the company at large.
Second there’s an option to ask for a reply explaining the transaction. Oversight will track whether or not the employee replies to the email and will provide notification if a reply is not received within a defined number of days. Often our users will escalate to the employee’s manager when there’s not a reply to the email. This built-in email feature allows for easy communication, and also serves as a built in compliance log of the out-of-compliance spending in case of an audit, FCPA inquiry, or HR action if the bad behavior turns out to be intentional and rampant.
Of course, you an always try to audit expenses and send emails manually yourself, but the beauty in having an automated tool that does all the heavy lifting for you is two-fold. First, you rest easy knowing 100% of transactions are being monitored for non-compliant behavior, and second many Oversight users see a reduction in out-of-policy spending simply because their employees know they are being watched.
The Hawthorne Effect can be a powerful way to catch attention, with very little effort.