Creating A Culture Of Compliance

Dear Import/Export Compliance Manager,

It seems that so much of my job consists of fighting fires.  As the saying goes, “An ounce of prevention is worth a pound of cure”, right?  How can I get my colleagues to buy into the trade compliance mindset and quit doing all of the things that just create headaches and risk for me, them and the company?

Flustered in Flushing

Dear Flustered,

Few are the import/export compliance professionals who do not spend at least some of their time fighting fires.  The reasons can be many including, as you state, lack of buy-in from other employees, lack of process or lack of visibility on the part of the Import/Export Compliance Department.  Regardless, you and most of your import/export compliance counterparts find yourselves so often being reactive instead of proactive and thus unable to make headway in the quest to prevent problems from occurring in the first place.

Thus, the end goal is to never have to deal with any fires.  But how do you achieve this?  In the opinion of the Import/Export Compliance Manager, the answer has three components: process, buy-in to that process and the means to enforce compliance.  Let’s address each in turn and see if there are any nuggets of wisdom in the analysis to assist you.

Let’s start with process.  Think of the point of view of the engineer wanting to ship a piece of equipment from the U.S. to India.  What is that engineer’s chief goal?  Get the shipment done as quickly as possible so she can get back to her regular job.  You may think that process can be an evil word but really, process is your friend.  A good, easy-to-follow and easy-to-find process that your co-workers understand and follow provides them something valuable: security.  The engineer can be secure in knowing that she is following the exact steps laid out by the people paid to be experts on it: the Import/Export Compliance Department.  That way, if there is a problem later on, she can always say that “Hey, I followed your process” and potentially not be blamed.  From your side, process a) will make it much harder for problems to occur and b) will allow you to, if necessary, bust someone’s chops (but not in a soul-crushing way).  You gave them the exact steps to follow, they skipped a step and now there’s a fire. 

OK, so now buy-in.  What’s the easiest way to get buy-in on a process?  Solicit input from the stakeholders (i.e. the people who will follow your procedure or otherwise be impacted by it)!  When you work together with, say, Technical Support, to develop or improve a procedure, they will a) be more cooperative because you are valuing their opinions, b) help craft a better procedure because they know their internal processes much better than you and how your proposed requirements would really affect them and c) will be more likely to suggest improvements, point out holes and lean on others within the department who might be trying to cut corners.  Even if you can’t bring in everyone that is affected, the fact that you can tell the stakeholders that the process was a work of multiple departments will give the process valuable credibility.

Lastly, you will need the means to enforce the use of the procedures.  Getting buy-in is being the ‘good cop’ but, as everyone knows, the ‘good cop’ on those cop TV shows often can’t get anything done without the ‘bad cop’.  Someone at some point is, for whatever reason, not going to follow your procedure.  Maybe they are in a hurry.  Maybe they forgot about it.  Maybe they are the type of person who thinks that compliance is a four-letter word.  Maybe they think that they are too important to be reprimanded.  Too bad, so sad; everyone should be at least notified that they deviated from the process and consulted to find out why.  If it was a case of bad acting, their manager should be made aware of the situation.  This is even more important when it is someone important who has committed a transgression; when workers farther down in the corporate hierarchy see someone above them not following the process and not getting reprimanded, it can do one of two things.  First, it can make those other employees less likely to follow your process and two, it can make it seem like there is a set of rules for upper management and ‘important’ people and a set of rules for everyone else.  Even if there really is a set of rules for upper management versus everyone else, don’t let compliance be caught up in it.  If you can make import/export compliance an exception to that rule, it sends an even more powerful message with regards to how important the function is.

Of course, knowing the framework for being proactive is great but is nothing without the resources to go do it.  Many departments are so far behind and strapped for resources that all they can do is rush from fire to fire.  The Import/Export Compliance Manager is a strong proponent of making the case for additional personnel, even temporary ones, and IT resources to help get over the hump of being reactive by creating procedures to be proactive.  And imagine the wonderful things your department can do when you actually have time to make real improvements!  Good luck!