We now turn our attention back to my series on Effective Policy Management & Communication.
In the previous posting we looked at the disarray and chaos of how policies are managed, maintained, and communicated within organizations. Often inconsistent, poorly written, out of date, lacking consistency, developed with no style guide, and ineffectively managed and communicated – corporate policy management in most organizations is a mess. Now we will turn from our flogging of the corporate policy mess to constructively developing an effective policy management process.
The first point to clearly understand – policies, done right, articulate the corporate culture.
Unfortunately, most organizations have not connected the world of policies to how they influence and establish corporate culture. Granted – corporate culture is there with or without policies. However, without policies there are no written standards as to what is acceptable and unacceptable conduct. Culture is allowed to morph and change without policies. The organization can quickly become something it never intended.
Policies provide a definition of the boundaries of the organization. At the the highest level it starts with the Code of Conduct laying forth ethics and values that extend across the enterprise. These filter down into specific policies at the enterprise level, down into the business unit, then department, and to individual business processes. Policies are supported by procedures. Both policies and procedures at the statement level establish and authorize controls by which the organization is closely managed and monitored.
Policies articulate the culture of compliance. They define what is acceptable and unacceptable. This starts at the ‘Mandated Boundary’ level of communicating what is right or wrong legally and how the organization will stay within legal boundaries within the various jurisdictions that it operates in. Policies then extend to the ‘Voluntary Boundary’ level to articulate what is acceptable and unacceptable when it comes to matters of discretion – ethics, values, code of conduct, corporate social responsibility, and other areas. Both the mandated and voluntary boundaries are written into policies so that individuals within the organization and its relationships know what is acceptable and unacceptable. It should not be open to broad discretion and interpretation.
Policies articulate the culture of risk. Every organization takes risk, it is part of business. Without clearly written guidance as to what is acceptable and unacceptable risk the organization is like a ship without a rudder. Policies provide clear guidance on what is acceptable and unacceptable risk, define risk acceptance and tolerance levels, and establish who owns and manages risk.
Please do not misunderstand me – policies are not a magic answer to culture, governance, risk, and/or compliance. Not at all. An organization can have a wide array of policies that are not adhered to and end up in very hot water. Policies ARE a way to clearly define, articulate, and communicate what the boundaries, practices, and expectations of the organization are. While you can have a horrible culture with policies, you cannot have a strong and established culture without them. The right policies are necessary to define and communicate what the organization is about.
Culture itself is broader than policies – policies are the vehicle that communicates and defines culture so that culture does not morph out of control. This requires that policies be adhered to, exceptions closely managed, and violations dealt with.
Over the next several weeks we will continue to look at Effective Policy Management and Communication. We will specifically explore:
- What is the right number of policies?
- Defining a process lifecycle for managing policies
- Establishing policy ownership and accountability
- Providing consistency in policies through consistent style and language
- Communicating policies across extended business relationships
- Tracking policies attestation and delivering effective training
- Monitoring metrics to establish effectiveness and/or issues with policies
- Relating policy management to risk, issue/case, and other GRC areas
- Using technology to manage and communicate policies
In addition to this series on policy management, Corporate Integrity is also offering a full-day workshop on the topic of Effective Policy Management and Communication.