The Importance of Effective Policy Writing for Compliance

Last week I was reviewing a company’s supply chain code of conduct which was sent to thousands of distributors around the globe. It was not impressive. Cluttered with unnecessary and complex language, it featured lengthy paragraphs and heavy use of the passive voice. It was written in English but distributed in China and Russia — ignorance of international audience was also a big problem. Further, one paragraph described “the organization’s only mission” and then another paragraph began “One of the organization’s missions,” showing that the organization itself is in need of a consistent policy.

Why it is imperative to have a clearly-written policy? Policy engagement starts with (effective) policy writing, which is the foundation for an effective code of conduct. A policy basically defines the general business guidelines by which the organization operates. Policy, as laid out in a clearly written code of conduct, establishes the compliance and ethics practices on an enterprise-wide level, which can be further distilled into procedures that define ongoing process of work.

Emphasizing effective policy, Carole Switzer, president of the Open Compliance and Ethics Group, raises the question, “When we are trying to engage employees without overloading them with policies, how can we make sure that each employee gets what they need and no more?” She further adds, “In the past, a big challenge has been keeping policies fresh and making sure people aren’t accessing and using old data. How does automation in a policy system address these issues?”

In Policy Engagement Starts With Policy Writing, Michael Rasmussen, Principal Analyst with GRC 20/20 Research, suggests that a good policy should;

• Articulates corporate culture
• Shows that the organization cares about policy
• Demonstrates professionalism
• Avoids expensive misunderstandings
• Aids those that struggle with reading or do not speak the language natively
• Provides consistency across policies

I agree whole heartedly what Michael has written. I also believe that organizations should focus on systematic and timely review of their policies. Let’s say a review every six months or a year would work best. We have many examples in which policy documents are never touched for years or even decades. Not reviewing one’s polices for long time not only hampers the development of organizational practices but also raises barriers to the understanding of employees and their career growth at a company. An organization should ensure that every employee receives a copy of new and existing policies, as well as updated policies, as soon as they become available.

But simply handing our copies of policies is not enough. If possible, every time, train employees on the new policies. David Childer, CEO of Compli, believes that employee success is based on good policy training. He says, “Delivering training and policies at the point of need isn’t the wave of the future; it is now.”

To avoid problems and confusion, ensuring that correct and timely information is given to everyone should be the organization’s focus. Properly written policy in plain language, with translations provided if needed, written in an active voice, and, importantly, with the understanding that policies should be reviewed regularly are the best solutions to stay organizations current and compliance effective.

Don’t you think it is the time to review your policies now?

Muhammad Talib Uz Zaman is a Program Officer for CIPE Pakistan.