Best Practice and Delivering Value – The Future for Compliance
Setting the Compliance strategy and priorities – aligning with the business
There was a trend, which seems to have gone out of fashion to some extent, for organisations, and even departments within organisations, to draw up ‘mission statements’, for public display and communication. We have come across quite a few Compliance Departments with mission statements, all of which have been perfectly laudable being centred around the fundamental requirement that:
“We are here to help our parent organisation stay out of regulatory trouble.”
This is, of course, an absolutely fitting and indeed essential objective for all Compliance Departments. But we observe that many of the more interesting Compliance functions have developed a strategy that goes well beyond avoiding regulatory problems. Other objectives have become an integral and vital part of their raison d’être:
“Compliance has become accepted as more than a cost of business. Increasingly it has been regarded as a codification of good business practice, which provides real value in terms of customer confidence. Good compliance should be indivisible from good business practice.”
Deborah Glass, Chief Executive4
Helping the firm implement its strategic objectives
Acting as the ‘champion’ of the consumer
Providing the sales force and back office customer-facing personnel with training, support and guidance
Acting as the liaison between the firm, the FSA and other statutory bodies
Helping the firm achieve quality of service and product (however ‘quality’ – a loaded word – is defined)
These objectives, however they are articulated and communicated, seem to go quite a way beyond the obvious one of avoiding regulatory censure, and have an intimate connection with the firm’s business strategy and success. There is an awareness that in an industry that is, for the foreseeable future at least, driven and shaped by regulation, the Compliance Department has a fundamental role to play in helping the firm steer a path that is commercially viable and sustainable.
The key to Compliance’s role in this regard is the simple truth that regulation, but particularly conduct of business regulation, is an expression of how the customer would like to be treated, whether the customer is an individual investor (in the case of retail firms), or a distribution business (in the case of product-manufacturers and other business-to-business concerns).
Getting the customer experience right is the principal interest of the Sales Director, the Strategy Director, the Marketing Director, the Training Director, and ultimately the entire senior management team. It is inevitable therefore that the Compliance function, for which achieving the desired customer experience is an almost overriding concern, will find itself involved in discussions related to the business as a business.
4 IMRO Annual Report 1999/2000, July 2000.