Katrina A. Bramstedt (email@example.com) is Head of Advisory & Training, Your Call, located in Kew, Victoria, Australia.
Posters with inspiring quotes, a toll-free hotline, and a sleek website hosting a code of ethics don’t mean much when the company is a toxic workplace, bullying is ignored, work-life balance is a fantasy, and “ethics” is viewed as a time and innovation impediment. If your company performs like this, it is time for a surgical makeover, as the compliance program is merely cosmetic.
The problem with cosmetic compliance programs
Cosmetic compliance programs tick many boxes in that they appear robust, but as with all cosmetics, underneath is the reality that shows its face eventually. Sometimes, cracks in the cosmetics appear during an audit, when cases are found to have been received but not followed up on or disregarded without due analysis, poorly investigated in the setting of conflict of interest, or meaningful corrective action was sidelined. Cracks also appear when whistleblowers immediately take their cases to lawyers or the media. In the short term, cosmetic compliance programs are low cost and simple to implement and operate, yet personal and corporate damage are festering underneath the camouflage.