FCPA Compliance and Ethics Blog

August 7, 2015

Social Media Week Part V – Tools and Apps for the Compliance Practitioner

Social Media 5-IconsTo conclude this week’s posts, I wanted to list some of the more prevalent social media tools, explain what they are and how you might use them in a compliance program. (As usual I got carried away so this series will conclude on Monday of next week.) You need to remember that your compliance customer base are your employees. The younger the work force, the more tech savvy they will be and the more adapted to communicating through social media. According to Social Media Examiner’s 2015 Social Media Marketing Industry Report, the top two social networks for marketing are Facebook and LinkedIn. The three social media tools that hold the top spot for social media planning are LinkedIn, YouTube and Twitter. Marketers report that video streaming is becoming increasingly important tools for markets and that is currently encompassed in Meerkat and Periscope. Finally, I would add that Pinterest is another hot social media app.

Facebook

If you do not know what Facebook is at this point, you may have just transported down from a Borg Cube or perhaps you are a Vulcan looking for First Contact. This is the world’s most ubiquitous social media tool. It combines both personal and business applications. For the compliance practitioner, think about the business uses of Facebook. You can open a Facebook page for your compliance function and share an unlimited amount of information. Equally importantly, you can be responsive when employees comment on your posts, it allows you to interact with them and demonstrate that compliance is listening and responsive. The more regularly you post, the more opportunity you have for connecting with your employee base and building trust.

YouTube 

Much like Facebook, YouTube is one of the most ubiquitous social media tools around. It allows you to upload video and audio recordings for unlimited play. For the compliance practitioner, why not consider creating a YouTube channel for your company’s compliance program. You can put together full training on specific issues or you can create short videos. For an example of short videos, you can check out the training videos I have on my website Advanced Compliance Solutions. If there is any information that you wish to put into a visual format, YouTube is one of the best solutions available to you.

LinkedIn

LinkedIn is almost as ubiquitous as Facebook and YouTube. As with Facebook, you can set up a business site or even a private compliance group for your organization. Your employees are the best place to start adding followers, as they are not only your target audience but they are also your biggest advocates. You can encourage employees to add their compliance profile to their personal profiles. By doing so, they automatically become followers and can like, comment on, and share your company updates to help expand your viral reach. As with Facebook, LinkedIn provides you a platform to communicate with your employee base. It has a chat function that can be used to solicit feedback and comments going forward. You can also tie in with or ‘link to’ other groups and people that can facilitate not only creating but also expanding your culture of compliance.

Twitter

Earlier this week, I wrote about how you can use Twitter to capture information from the marketplace of ideas. However Twitter can also be used for communicating with your employee base. Tweets are publicly visible by default, but senders can restrict message delivery to just their followers. Users can tweet via the Twitter website, compatible external applications or by Short Message Service (SMS) available in certain countries. Retweeting is when users forward a tweet via Twitter. Both tweets and retweets can be tracked to see which ones are most popular. Finally, through the use of hashtags (#) users can group posts to Twitter together by topic.

I believe that Twitter is one of the most powerful tools (and completely underused tools) that is available to the compliance function. If employees follow their company’s name through a hashtag, they can see what trending topics other employees are discussing. Compliance practitioners can help lead that internal discussion through the same technique. Moreover, if the Chief Compliance Officer (CCO) or compliance function regularly monitors Twitter they can keep abreast of any communications and those can be used as a backup communication channel, in case the company hotline or other reporting system is not immediately available or even convenient.

Meerkat and Periscope

Two of the newest and perhaps coolest tools a CCO or compliance practitioner can utilize in the realm of social media are Meerkat and Periscope. Both tools allow you to tell a compliance story in real time, throughout your organization and beyond through the capture and broadcast of video, live through your smartphone. They are both live streaming apps that enable you to create a video and open the portal to anyone who wants to use it. Anybody in your Twitter community can click on that link and watch whatever you’re showing on your phone. The big piece is the mobile aspect. It is as simple as a basic tweet and hitting the “stream” button.

This is one of the more exciting new social media tools I see for the compliance practitioner. You could start a compliance campaign along the lines a campaign that the company Hootsuite initiated called “Follow the Sun” using Periscope. They decided to let their employees showcase what they called #HootsuiteLife. They gave access to different people in every company office around the globe. Throughout the day, it would “Follow the Sun,” and people in different offices would log into the Hootsuite account and walk around and show off their culture, interviewing their friends, etc. They talk about the importance of culture and now they are proving it. The number of inbound applications drastically increased after people got that sneak peek into their company. You could do the same for your worldwide compliance team.

You can live stream video training around the globe. Moreover, if you use either of these tools in conjunction with internal podcasting or other messaging you can create those all important “Compliance Reminders” which were so prominently mentioned in the Morgan Stanley Foreign Corrupt Practices Act (FCPA) Declination. The videos that you create with both of these tools can be saved and stored so a record of what you have created can be documented going forward.

Pinterest

According to Pinterest for Dummies, this tool is an online bulletin board, a visual take on the social bookmarking site, where the content shared is driven entirely by visuals. In fact, you cannot share something on Pinterest unless an image is involved. When you share something on Pinterest, each bookmark is called a pin. When you share someone else’s pin, it’s called a repin. Your group pins together by topic onto various boards, aka pinboards, in your profile. Each board mimics a real-life pinboard. You can share images you find online, or you can directly upload images. Using the “Pin It” button, you can share directly in your browser from any web page. You can also share your pins on Twitter and Facebook.

Although a relatively new social media tool, I find it to be one of the more interesting ones for use by the compliance function as it compliments many of the other tools I discussed above. You can set up your compliance account for your organization and pin items, lists, or other visual information that can be viewed and used by employees. In addition to the enumerated items, you can pin such things as a link, a website, graphics or other forms of information. If you think of it as an online bulletin board, you can consider all of the compliance information that you can post for your customer base and the interactions they can have back with you.

All of these tools can help you as CCO or a compliance practitioner to engage with your customer base. On Monday, I will conclude with some final thoughts on why the compliance function should use social media tools available to them.

Once again please remember that I am compiling a list of questions that you would like to be explored or answered on the use of social media in your compliance program. So if you have any questions email them to me, at tfox@tfoxlaw.com, and I will answer them within the next couple of weeks in my next Mailbag Episode on my podcast, the FCPA Compliance and Ethics Report.

 

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

 

© Thomas R. Fox, 2015

August 5, 2015

Social Media Week Part III – Twitter and Innovation in Your Compliance Program

Social Media III. TwitterI continue my exploration of the use of social media in your Foreign Corrupt Practices Act (FCPA) compliance program today. One of the ways that Chief Compliance Officers (CCOs) and compliance practitioners can communicate about their compliance programs is through the use of the social media tool Twitter. In an article in the Summer issue of the MIT Sloan Management Review, entitled “How Twitter Users Can Generate Better Ideas”, authors Salvatore Parise, Eoin Whelan and Steve Todd postulated that “New research suggests that employees with a diverse Twitter network – one that exposes them to people and ideas they don’t already know – tend to generate better ideas.” Their research led them to three interesting findings: (1) “Overall, employees who used Twitter had better ideas than those who didn’t.”; (2) In particular, there was a link between the amount of diversity in employees’ “Twitter networks and the quality of their ideas.”; and (3) Twitter users who combined idea scouting and idea connecting were the most innovative.

I do not think the first point is too controversial or even insightful as it simply confirms that persons who tend have greater curiosity tend to be more innovative. The logic is fairly straightforward, as the authors note, “Good ideas emerge when new information received is combined with what a person already knows.” In today’s digitally connected world, the amount of information in almost any area is significant. What the authors were able to conclude is that through the use of Twitter, “the potential for accessing a divergent set of ideas is greater.”

However it was the third finding that I thought could positively impact the compliance profession, the role of the Idea Scout and the Idea Connector. An idea scout isan employee who looks outside the organization to bring in new ideas. An idea connector, meanwhile, is someone who can assimilate the external ideas and find opportunities within the organization to implement these new concepts.” For the compliance practitioner, the ability to “identify, assimilate and exploit new [compliance] ideas” is the key takeaway. However to improve your compliance innovation, “you need to maintain a diverse network while also developing your assimilation and exploitation skills.”

For the compliance practitioner, Twitter can be “described as a ‘gateway to solution options’ and a way to obtain different perspectives and to challenge one’s current thinking.” Interestingly the authors found that “It’s not the number of people you follow on Twitter that matters; it’s the diversity within your Twitter network.” The authors go on to state, “Diversity of employee’s Twitter network is conductive to innovation.” Typically an Idea Scout will “identify external ideas from experts and resources on Twitter.” Clearly the compliance practitioner can take advantage of experts with the anti-corruption compliance field but there is perhaps an equally rich source of innovation from those outside this arena.

An interesting approach was what the authors called the “breadcrumb” approach to finding innovation leaders and thought-provokers. It entailed a “period of “listening” to colleagues and industry leaders who are on the platform – including what they are tweeting about, who they are following and replying to on the platform, who is being retweeted often”. So with most good leadership techniques the first key is to listen.

Equally important to this Idea Scout is the Idea Connector, who is putting the disparate strands from Twitter’s 140 character tweets together. For the compliance function, this will be someone who identifies compliance best practices or other information from Twitter ideas, can then put them together and direct the information to the relevant company stakeholders. Finally, such a person can “Curate Twitter ideas and matches them with company resources needed to implement them.”

Here the authors listed a variety of ways an Idea Connector can use Twitter. One user said, “I try to sift through all the Twitter content from my network and look for trends and relationships between topics. I put my analysis and interpretation on it. I feel that’s where my value-add is.” Another method is to focus on analytics and one user “filtered specific subsets of the topic for different stakeholders” at his company. Another method was to create “social dashboards or company blogs based on the insight” received thought Twitter. Interesting, one of the key requirements for successfully mining Twitter was in finding ways to share its content “since many employees, especially baby-boomers don’t use the platform themselves.” Conversely by mining information from Twitter and presenting it, this can allow these ‘technologically challenged’ older employees to ascertain how they can target millennial’s.

But as much as these concepts can move a CCO or compliance practitioner to innovation in a compliance program, it can also foster additional information through the following of your own employees. It is well known that Twitter can facilitate greater communication to and between the compliance function and its customer base, aka the company employees. However the authors also point to the use of Twitter to enable this same type of innovation because it “is different than email and other forms of information sources in that it enables continuous engagement”.

Twitter was created to allow people to connect with one and other and communicate about their activities. However the marketing potential was immediately seen and used by many companies. Now a deeper understanding of its use and benefits has developed. For the compliance practitioner one thing you want to consider is to align your Twitter and great social media strategy with your compliance strategy; match your Twitter strategy to your compliance strategy.

Twitter can be powerful tool for the compliance practitioner. It is one of the only tools that can work both inbound for you to obtain information and insight and in an outbound manner as well; where you are able to communicate with your compliance customer base, your employees. You should work to incorporate one or more of the techniques listed herein to help you burn compliance into the DNA fabric of your organization.

Once again please remember that I am compiling a list of questions that you would like to be explored or answered on the use of social media in your compliance program. So if you have any questions email them to me, at tfox@tfoxlaw.com, and I will answer them within the next couple of weeks in my next Mailbag Episode on my podcast, The FCPA Compliance and Ethics Report.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2015

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