Creating effective compliance programs.

• Author: Bejarano, Jessica
• Position: Ethics Corner

Enforcement of government contract regulations has become increasingly vigilant. An effective compliance program, as opposed to one that looks good on paper and sits on the shelf, is critical to satisfying and exceeding the U.S. government's requirements.

An effective compliance program should be incorporated into and visible within a company's culture. Employees should understand the company's core values, practice them and speak up when they have a concern.

The foundation of any program is consistently communicating to employees the importance of compliance. Like many other government contractors, PAE's workforce comprises many nationalities, languages and cultural norms, which can present a challenge to effective communication. With such a diverse workforce, the definition of the gold standard in ethics can be interpreted differently across various cultures.

For example, gratuities that are highly regulated in the United States may be viewed as a minimum courtesy in other parts of the world. With differing cultural norms and a matrix of regulations that apply in certain locations, communicating a universal message regarding the importance of compliance with relevance to all employees is a balance of art, science and legal acumen.

Against this milieu, PAE has relied on several touchstones.

First is the need to talk about the issues. Many companies require employees to participate in annual compliance training. While standardized training serves a purpose, it is very effective to host compliance risk discussions specific to our industry with our managers. A two-way discussion of the real-life scenarios and mitigation tactics can often be much more useful than the hypothetical examples in a training program.

Following these discussions, managers can provide the takeaways to specific employee populations that would find the message relevant. With this practice, companies invite managers into the process and create additional compliance stewards who can help communicate requirements, and identify and manage risks when they arise.

It is also important to establish common ground. With any workforce, it is important to demonstrate inclusiveness and respect diversity, while at the same time highlighting the common core values. While celebrating the company's diverse cultures, everyone must understand that all employees wear the same company color" and are expected to respect and uphold the company's values.

Also, technology should be leveraged...