At News Corp, we identified this as a gap in our program, also from having read the evaluation of corporate compliance programs, which you also highlight in your report. So, over the past year, we’ve devised an entire toolkit for managers about what compliance means for them. It’s really three short micro-learnings, because we know that short is the way forward now. The first one is, “What does compliance mean for managers?” The second one is, “How do you drive a culture of compliance amongst your team?” and the third is, “What is a manager’s role when someone speaks up?” Ultimately, what does compliance mean for managers? We think it’s to lead by example. Walk the walk, read the policies, do the training. I mean, these sound obvious, but they’re not obvious because in some of the major incidents that I’ve seen, it’s the managers who, if they knew exactly what their roles and responsibilities were, would be better placed to ensure that those issues wouldn’t have occurred in the first place. And again, it goes back to accountability, doesn’t it? Everybody taking ownership of compliance rather than the compliance function trying to do everything, which inevitably it can’t be expected to do. I think first and foremost, what is key here, and you really stress in your report as well, is that risk management perspective. Know the risks in the area that you manage. Involve your team in identifying those risks, understand
the compliance controls that mitigate those risks and identify, learn and summarize relevant policies and processes. It’s almost like an ongoing risk assessment all the time that has to be done at that manager level. TF: Was there anything in the report that surprised you? IH: I think surprise might not be the word. I genuinely wasn’t surprised by anything, but the one area of the report, which is probably the hardest thing to do — but I don’t know whether I’ve ever seen the panacea of an answer that gets us close — is, how do you measure the effectiveness of “I don’t know whether I’ve ever seen the panacea of an answer that gets us close ... [to] how do you measure the effectiveness of your program? We’ve all been around this question many, many times.” — Imogen Haddon News Corp chief compliance officer
24 | April/May 2024
Q&A: Ty Francis + Imogen Haddon
CCI Magazine
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