Supervise: Monitoring the Enemy and the Troops

Supervise: Monitoring the Enemy and the Troops
It's time to do what strong programs do best: monitor the battlefield and our own ranks. 

Don’t overlook internal threats. While external breaches tend to get the headlines, it’s often the internal issues, such as fraud, misconduct, or weak controls, that lead to organization failure. 

With your core compliance components in place, what comes next is just as critical. You supervise.

Here are some essential touchpoints to ensure that you are effectively supervising your compliance program.

Monitoring the Enemy and the Troops

A compliance program is only as effective as its ability to detect misconduct. And in many organizations, the greatest threat doesn’t come from the outside. It comes from within. 

Internal misconduct evolves gradually. Desensitized employees. Unreported infractions. Even worse, a failure to respond to reported ones. Eventually, bending or ignoring the rules becomes normalized, and may even become part of your organization's culture.

Prevent this by supervising effectively once your policies and training are implemented. Begin by focusing on your high-risk areas. Leverage your controls, audit consistently, and document your findings. 

Don’t assume yesterday’s controls will catch today’s threats. As the environment evolves, so do risks. Monitor your organization proactively to better guard against emerging risks. Be intentional and progressive, and continue to improve upon and add to your controls amidst shifts in behavior, culture, risks, and operations.

Make Your Performance Reviews Count

Annual performance evaluations are one way to assess KPI’s, but they can also be used as an opportunity to monitor your organization’s culture.

Use the performance evaluation process as a two-way communication channel. While employees receive clarity on their own performance, organizations can gain insight to how employees perceive corporate culture by asking thoughtful questions. 

Incorporate standardized, yet targeted questions into the process. Train managers to ask employees if they’ve witnessed anything that felt off or made them uncomfortable: misconduct, pressure to violate policy, or behavior that simply didn’t align with personal or corporate values. These conversations reveal what audits and checklists miss.

Equip the Front Line

Employees should never wonder how to report a concern. Make reporting easy for your employees. If employees have to scramble for the right contact or platform, they may delay their report. They may even choose not to report at all. 

Eliminate these barriers by making sure that the reporting process is simple and accessible. 

Establish a hotline or a website where employees can go to for compliance guidance or report concerns.  Publicize it. This reporting mechanism should be clearly and frequently communicated across the organization. It shouldn’t be simply introduced once, but consistently reinforced by telling employees you want to hear from them. 

Employees must also be trained on reporting. Train them on what kind of issues require reporting, and how to use the system appropriately. 

To ensure accessibility, trust, and eliminate barriers, allow anonymous reporting and offer the platforms in all primary languages used by your workforces.

Follow-Up and Follow-Through

Retaliation, whether subtle, or overt, is one of the most significant deterrents to employee honesty. 

Monitor for retaliation by checking-in with reporting employees. 

Set up post-report checkpoints at one week, one month, and again during their next performance review. Ask questions: Are you okay? Have you experienced any retaliation?

Asking these fundamental questions reinforces your commitment to your employees.

The Exit Interview—Your Last Line of Truth

Departing employees are often the most candid. With less concern about retaliation, they are more likely to speak openly about their experiences. Exit interviews present a valuable opportunity to uncover concerns that may have not been raised through formal reporting channels. 
Ask departing employees whether they witnessed or experienced misconduct or anything they believed was unethical during their employment. The responses you receive may offer one of the most unfiltered views into your organization’s culture and compliance climate.

Final Word

Monitoring isn’t about suspicion or micro-managing. It’s about the importance of being vigilant and ensuring the controls and compliance program elements you put in place are actually effective. It’s reflective of your organization's commitment to integrity. 

Monitor for wrongdoing while you work to minimize it. Foster an environment where doing the right thing is rewarded, and where employees feel invited to raise concerns. 

A culture built on integrity is one where compliance is sustainable, not performative, but it does not materialize on its own. A strong compliance program - just like the battlefield - must include continuous monitoring for effectiveness.