When good apples turn bad, how to tackle this problem as a compliance officer

Compliance Tyler
3 min readFeb 27, 2024

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Addressing the issue of “good apples turning bad” in an organization, especially from a compliance perspective, involves a multifaceted approach aimed at preventing, detecting, and responding to unethical or non-compliant behaviour. Here are steps you, as a compliance officer, can take to tackle this problem:

1. Preventive Measures

  • Culture of Integrity: Foster an organizational culture that emphasizes ethical behaviour, integrity, and compliance. Leadership should lead by example, demonstrating a commitment to ethical principles.
  • Training and Education: Provide regular, comprehensive training on ethical behaviour, legal requirements, and organizational policies. Ensure employees understand the consequences of non-compliance.
  • Clear Policies and Procedures: Develop and maintain clear, accessible policies and procedures that outline expected behaviours and compliance requirements. Include guidance on how to avoid potential ethical pitfalls.
  • Effective Communication: Ensure open lines of communication where employees feel comfortable raising concerns without fear of retaliation. Implementing an anonymous reporting mechanism can be beneficial.

2. Detection Measures

  • Monitoring and Auditing: Implement systems to monitor compliance and conduct regular audits to detect unethical behaviour or policy violations. Use technology to your advantage by incorporating data analytics to identify potential red flags.
  • Whistleblower Systems: Encourage the use of whistleblower systems that allow employees to report unethical behaviour anonymously. Ensure these systems are secure, confidential, and that they protect the whistleblower from retaliation.
  • Risk Assessment: Regularly conduct risk assessments to identify areas of the organization that are more vulnerable to unethical behaviour. Adjust policies, controls, and training programs based on these assessments.

3. Response Measures

  • Investigation: Promptly and thoroughly investigate any reports of unethical behaviour or non-compliance. Ensure investigations are conducted fairly and objectively.
  • Disciplinary Action: Clearly communicate the consequences of non-compliance or unethical behaviour and follow through with appropriate disciplinary actions. This may range from retraining to termination, depending on the severity of the misconduct.
  • Continuous Improvement: Learn from incidents of non-compliance or unethical behaviour. Use these experiences to strengthen policies, training, and controls to prevent future occurrences.
  • Transparency and Accountability: Be transparent about the measures taken to address unethical behaviour or non-compliance. This can help rebuild trust and reinforce the importance of compliance within the organization.

4. Support and Resources

  • Provide Support: Offer resources and support for employees who may be facing ethical dilemmas or pressure to engage in non-compliant behaviour. This could include access to ethics advisors or counselling services.
  • Engage Stakeholders: Work closely with other departments, such as HR, legal, and audit, to coordinate efforts in promoting compliance and ethical behaviour. Engage with external stakeholders, including regulators, to stay informed on best practices and regulatory expectations.

As a compliance officer, it’s crucial to approach this issue proactively, establishing a robust compliance framework that not only deters bad behaviour but also promotes a positive, ethical culture. Continuous evaluation and improvement of compliance programs are essential to adapt to new challenges and ensure that the organization remains committed to ethical practices and legal compliance.

Disclaimer: The information provided herein is solely for informational purposes and represents my own personal views. It should not be construed as legal or regulatory advice. For advice specific to your circumstances, please consult a qualified professional. Additionally, the opinions expressed are my own and do not reflect the views of my employer.

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Compliance Tyler

Tyler Woollard is a Compliance Professional. Tyler writes these compliance blogs to drive the compliance conversation tyler.woollard@theconductmind.com