Peter has no time for rules, especially the pointless ones that add a lot of work for no apparent benefit. When he encounters such rules, his first thought is to find a workaround. Wendy doesn't mind rules - she'll follow them when she sees them. The problem is that she sometimes doesn't see them. Not that anyone minds - she's so brilliant at what she does that people are willing to overlook the little foibles. Well, no one is perfect but...
John comes pretty close. He's the kind of guy who reads the manuals that come with gadgets and always remembers to turn the lights off and lock the doors behind him. Occasionally, issues do crop up for him, too - but never anything significant.
What are the key compliance personas?
As a training provider, it is vitally important for us to understand the impact that our compliance courses have on employees. Our example above highlights each of the key compliance personas - the good, the bad and the ugly of individual behaviour:
- The Good - habitually compliant individuals who don't need much training. A quick refresher or a message from top management is all they need to keep their natural instincts sharp.
- The Bad - accidentally non-compliant individuals who are prone to be caught unaware, influenced by others, unclear about the rules etc.
- The Ugly - wilfully or deliberately non-compliant individuals who are unlikely to respond to compliance awareness and training. They need extra scrutiny and tough sanctions for violations.
Identifying compliance personas
You need to know where each individual sits on the compliance spectrum. But how easy is it to spot the different compliance personas in your company? And are these personas fixed, or do they change? For example, do people consistently comply in some areas but not in others?
Furthermore, do the habitually compliant always comply no matter what? Or could their behaviour change, for example, if under peer pressure or coerced by a colleague?
You need to identify the factors that determine whether someone is compliant, accidentally non-compliant, or wilfully non-compliant. And then tailor your strategies accordingly.
Fraud motivating elements:
- Incentive - this could be monetary problems such as debt, or it could be pressure from a colleague or manager
- Opportunity - if there is a clear course of action that minimises the risk of the crime being discovered
- Justification - An ability to rationalise the crime - if the person can justify the crime in a way that is acceptable to their own moral compass
How to manage each compliance persona
It's worth reviewing the sanctions imposed on people with different personas to decide if they are appropriate. For the deliberately non-compliant, a hefty fine may be just the ticket to prevent future acts of wilful non-compliance.
But is it fair to give the same punishment to someone who has always been ‘right first time’ or even someone who has committed fraud accidentally? While it may make them more careful in future, it may just cause resentment and even push them towards the deliberately non-compliant persona in the act of rebellion.
- Habitually compliant - Empower your 'right first timers' to act as a compliance champion and role model for others. Give praise and recognition and protect them from people who seek to undermine compliance or put pressure on them to act differently.
- Accidentally non-compliant - For those who are blasé or nonchalant about compliance, you need to foster a sense of ownership, community or CSR. Make it easier for these individuals to comply by reducing the opportunity for making mistakes or committing fraud.
- Wilfully or deliberately non-compliant - For those who are wilfully non-compliant, you need to be tough. You need to reduce the opportunities to make errors, and focus more on detection and increasing sanctions. The idea is to take action to move them to a less risky persona.
Creating a culture of compliance starts with understanding the people in your organisation, knowing how to identify the red flags, and having appropriate and effective training materials to engage each type of compliance persona.
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