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Alexandra Wrage
President and Founder, TRACE


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Nicola Bonucci 
International Lawyer and former
Director for Legal Affairs OECD
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Dave Lee
FCPA Compliance Consultant, TRACE
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Sunny McCall
Senior Director II, Compliance Training, TRACE
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Lee Nelson
Independent Compliance and
Ethics Attorney
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Jessica Tillipman
Associate Dean for Government Procurement Law, The GW University Law School
  • Writer's pictureLee Nelson

Compliance and HR Aligned: Better Together

In a prior post, we examined how middle management can act as a Compliance force multiplier. Aligning closely with your organization’s Human Resources (HR) department is another way to amplify your Compliance program and increase its stickiness with employees. Be forewarned: HR is not going to ring up and ask what it can do to help. Instead, Compliance must take the initiative by proposing and administering concrete steps that will leverage the power of HR’s continuous connection to the workforce.  Here are five such steps Compliance can take, and a couple of gotchas too:    

  • Do not take Compliance/HR alignment for granted. Start by  articulating to HR leadership the importance of strong alignment between your departments, emphasizing your shared goals.  Ask for HR’s commitment to create and operationalize a plan. If you sense hesitation, remember that HR is usually, and wants to be seen as, the champions of company culture. Stress that Compliance’s goal is to provide HR with tools and procedures so that it can better protect the organization’s ethical culture and reputation.   

  • Build and execute an employee lifecycle/touchpoints plan. Hold one or more Compliance/HR brain-storming sessions to discuss ideas and develop a plan to ensure Compliance concerns are addressed at each stage of the employee lifecycle – Onboarding, Working, and Exiting. There are several topics to address at each stage including the Onboarding training and policy acknowledgment process, content, and tracking; encouraging a speak-up culture for those Working in the office and remotely; and conducting interviews and confidentiality reminders for employees Exiting the organization.  Each department should designate a project leader responsible for implementing the plan’s action items with a timeline. Remember two points in designing and implementing a plan. First, HR is busy. There is much ado daily. Craft a plan that has actionable tasks and an agreed timeline for implementation. Second, HR teams have turn-over like other departments. Check-in regularly to ensure that what has been implemented continues to operate as planned.   

  • Be explicit about how HR should react in critical situations. HR employees often understand employment law principles and particular issues such as harassment, but they may be less familiar with legal woes arising from other types of employee behavior such as fraud, bribery, and theft of trade secrets. Provide in-person training about what HR should be on the look-out for, and what to do, or not to do, upon learning of allegations of illegal activities or policy breaches. Explaining the process of an internal investigation - communications, interviews and other evidence gathering – is important advanced preparation that also can help to tighten the Compliance/HR bond.   

  • HR Eyes & Ears. If you work in a large organization, chances are HR has employees in many more offices than Compliance. Ask HR leadership to designate local HR employees to act as local Compliance champions – your local eyes and ears about compliance matters in that office. To make this successful, Compliance must both provide broad training to the local champions to develop their ability to identify issues as well as check in regularly to maintain the open communication lines and ensure the local champions feel empowered. 

  • Conduct an annual alignment meeting. Invite HR to join Compliance annually to review the plans and projects you have implemented together, discuss improvements as well as new opportunities, and celebrate success.  

Creating a tighter alignment between Compliance and HR not only helps to accomplish the two departments’ shared mission to protect the organization and invigorate ethical decision-making, it also develops inter-departmental trust that strengthens the organization’s culture.    

Independent Compliance and Ethics Attorney



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