Coaching: Strong leadership is important, both from senior management and within the compliance group. The strength of the leadership and depth of support will, to a large extent, determine the effectiveness of the compliance program. Corporate Culture: The extent to which compliance monitoring is integrated into the activities of the company will have a significant impact on the confidence that management and OSFI can place in the work of the compliance group. If compliance is made a part of a company's values, and the way it behaves, the company should be in compliance with all relevant legislation. Communications: Ongoing communication from senior management builds a strong profile for compliance with employees and demonstrates the importance that management places on the subject. Consistent communication will also encourage the staff to carry out the program conscientiously. As well, upward communication from the staff will strengthen the confidence that management has in the control culture they are fostering. Finally, where the work is widely distributed around the organization a good communication program is needed to ensure that everyone is doing their job. Continuing education: The staff that monitors compliance must keep up to date with changes in legislation and new monitoring techniques. In fact education on compliance issues would be a useful addition to the training programs across the company — helping to install a strong compliance culture. Continuing education also sends a message that the company sees compliance as important. Cooperation and collegiality: This may sound like motherhood, but it is important to recognize that compliance is not a one-person job. To monitor and enforce compliance for a wide range of legislation, many people within the institution must cooperate and become involved. The participants must believe in the importance of the task. Source: OSFI (Office of the Superintendent of Financial Institutions, Canada) |