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The Behavioral Science of Compliance CUMPLEN.pdf

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The Behavioral Science of Compliance CUMPLEN.pdf

  1. 1. The Behavioral Science of Compliance http://sic2022.eventocompliance.com/ip Prof. Hernan Huwyler MBA CPA – Compliance Executive Education
  2. 2. How organizations decide to meet stakeholders´ expectations Organizational Psychology of Compliance How employees change behaviors at direct requests or influence of those in a position of authority Reflected in organizational objectives such as values, performance goals, discipline and incentives What is compliance?
  3. 3. Understanding how decisions are influenced has direct implications • How to avoid biases in assessing compliance risks • How to disclose conflicts of interests • How to assign accountabilities and responsibilities • How to articulate performance objectives • How to avoid fraud rationalization • How to design awareness and training campaigns Why behavioral science?
  4. 4. Availability • Old and unemotional breaches are not considered Confirmation • Factors conflicting personal beliefs are disregarded Overconfidence • Capabilities to control are overrated Over-optimism • Exposures to risk factors are underrated Group thinking • Conformity excludes minority views Present thinking • Long term risks are not a priority Biases in assessing compliance risks
  5. 5. Studies with compliance implications 1951 Asch Conformity Experiment > peer pressure • In minority, people conform to wrong answers 1971 Stanford prison experiment > Lucifer effect • Authority, roles and uniforms promptly result in abuses 1973 Milgram experiment > chain of command • Authority allows to hurt others even without explanations 2015 Heroic Imagination Project > whistleblower protection • Heroes can plan or react to combat abuses Why?
  6. 6. Ask for a large requirement expecting to be refused. Then, make a second request to the target compliance Start your compliance requests by • setting a conservative posture to interpret obligations • recommending compliance controls for full scope • benchmarking controls against international best practices • using a top-down implementation from headquarters After refusing the initial request, stakeholders will be more likely to feel compelled to comply with their second request Door-in-the-Face
  7. 7. Ask for a small commitment. Then, keep increasing requests to the target compliance Start your compliance requests by • testing pilots in the compliance initiative • implementing low-hanging fruit activities • increase the escalation of approvals and other controls • involve the smaller and collaborative business units After complied with the initial request, stakeholders will be more likely to also comply with larger requests Foot-in-the-Door
  8. 8. Signal your credible and knowledgeable authority When introducing compliance initiatives, • show your mandate given from the board • get introduced with credentials and achievements • engage subject matter experts for backup opinions • dress up and link your personal brand to reputable institutes Stakeholders will be more likely to be influenced by leaders Authority
  9. 9. Demonstrate that other groups of stakeholders are complying When deploying compliance initiatives, • show endorsement from top managers > social norming • use techniques and tools proven in the market • communicate positive evaluations and testimonials • share good compliance in peer companies and units • introduce a “compliance ambassador” program Stakeholders will be more likely to be influenced by the wisdom-of-the-crowd Social proof
  10. 10. Build your reputation as an approachable and easy to be followed compliance officer When changing compliance controls, • identify similar traits and goals with stakeholders • compliment attitudes and results of stakeholders • disclose your background and personal data • tell stories about your mistakes in compliance Stakeholders will be more likely to comply to requests done by similar employees Liking
  11. 11. Signal your credible and knowledgeable authority When closing compliance initiatives, • distribute awards as “I complied!” • make stakeholders to publically communicate values • address pushbacks with the stakeholders´ public commitments Stakeholders will be more likely to be consistent with the commitments they have previously said or done Consistency
  12. 12. • Ask employees to write when and where they will control • Add blank boxes for employees to describe their changes • Give feedback on compliance performance against peers • Send positive reinforcement to top compliance performers • Use names and different colors and formats for requests • Provide reasoning of why employees are asked to control • Politely explain procedures, recourse options and incentives • Inform negative consequences of inaction • Present reputable sources of the requests • Explain the most important request at the top • Articulate small tasks for the complex requests INSPIRE Framework 2017
  13. 13. • Train on compliance scenarios and dilemmas > two-ways • “Co-create” principle-based policies with waivers • Articulate controls in single responsible and accountable roles • Get signed acknowledgments after receiving notes • Communicate cases of policy violations and misconduct • Allow fearless reporting of breaches, errors and whistleblowing • Explain the effect of breaches on personal careers • Periodically repeat key messages in training and awareness • Follow a change curve with stakeholder management tools • Do a deep root-cause analysis on breaches • “Put a face” to people affected by employee decisions • Create forums to discuss how to meet obligations Tips
  14. 14. Avalado por: OPEN QUESTIONS http://sic2022.eventocompliance.com/index_v3.php#ponentes

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