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GRC Professional : GRC Summer 2012
IN THE OFFICE 32 GRC Professional • Summer 2012 from a staff member – lack of understanding of which is a common cause of whistle blowing program failures). AIA Group became the first Asian Principal Member of ACI and a close partnership was formed, including creation of a learning and development curriculum incorporating ACI qualifications for AIA Group compliance staff, Group-wide. Four members of the Compliance Learning Academy team – all learning professionals – qualified as ACI Compliance Associates. Overall group scores on culture of compliance and ethics questions included in the Employee Engagement survey increased from 2009 to 2010. Amicable separation Despite the achievements arising from the partnership, natural organisational structure pressures and a drive for efficiencies ultimately led (on a restructure of the Group human resources department) to the Compliance Learning Academy team being assumed back into the mainstream Learning and Development team within the human resources department. However, the separation proved to be an amicable one. The integrated model had achieved its key objectives (i.e . the need to meet critical compliance and ethics initiatives fast) and although the rationale for the fully integrated model was no longer present, there remained a continuing commitment on the part of management and the human resources department that compliance learning initiatives remain important for the organisation and delivery would continue to be supported by human resources. Although not all compliance departments will be able to justify implementation of an integrated model, there are some lessons that others might take from AIA’s experience. Close partnership or integration might be considered and be able to be justified on a project or working group basis if critical compliance learning deliverables need to be implemented in a short period of time. Compliance officers, given their experience, may not necessarily make the best trainers. It should not be assumed that technically qualified compliance officers automatically know how to train others. Where an organisation has a pool of talented trainers in the human resources department, it is almost a shame not to tap into that resource for their specific expertise to help ensure compliance training is delivered effectively and is aligned and integrated with other corporate training. And seeking HR’s assistance on the basis that you need their superior skills and expertise may help you better secure it! Secondment (of compliance officers to the HR team or vice versa) might be considered so that compliance officers, if they have to deliver training or develop training modules, are better skilled to do so. Rather than separate surveys to assess the culture of compliance in your organisation, consider incorporating relevant questions in HR-led engagement surveys so that you go to your staff only once. Your HR platform may offer functionality to enable the roll out of e-learning modules. Avoiding separate systems can make the process simpler for users. Strong cooperation between the compliance and human resources departments, if not an integrated partnership, will certainly help break down departmental silos and move the organisation closer to the pearly gates of ‘culture heaven’. ••• Rather than separate surveys to assess the culture of compliance in your organisation, consider incorporating relevant questions in HR-led engagement surveys so that you go to your staff only once.
GRC Spring 2011
GRC Autumn 2012