ACM study into compliance culture at businesses in regulated markets

The Netherlands Authority for Consumers and Markets (ACM) has conducted a behavioral study into the compliance programs and compliance cultures in four regulated businesses. In that study, we did not only examine whether everything was all right ‘on paper’, but employees and management, too, were asked about rules and regulations. These concerned rules and regulations that ACM enforces. The study revealed that compliance culture in the companies that were studied is in order. In a healthy compliance culture, rules and regulations are complied with, and a culture exists where doubts and mistakes are openly discussed.

The following methods are recommended that help realize a healthy compliance culture:

• Lead by example, that is essential, the ‘Tone at the top’ determines the compliance culture. Executives and managers play a critical role in promoting compliance, supporting compliance, and being compliant themselves.
• Offer workshops (mandatory or not) tailored to the target audience, repeat these often, and refresh that knowledge.
• Promote both internal compliance as well as a compliance culture in which errors can be made. These support and enhance each other.
• Create a team of visible compliance experts, and give them sufficient influence.
• Handle complaints and reports confidentially and with care.
• Take seriously any psychological barriers to filing reports that employees can face.