GRC Journal - (Page 72) Governance, risk & Compliance KEEPING PACE OR wINNING THE RACE EITHER wAY, YOU NEED TO KNOw wHERE YOUR PEERS ARE By CAroLe S. SWiTZer, executive vP and General Counsel, oCeG Marathon runners say, “Plan the race, and race the plan.” You need to know what your objectives are and what obstacles you must overcome to develop the right plan of attack. How have others tackled the course? How many hills are there? How fast are your competitors? Is your goal to win, to set a new record or merely to cross the finish line with a personal best time? Only when you answer these questions and more can you determine how to set your speed and decide which runners to pass or pace yourself against. It all comes down to objectives and obstacles – knowing what they are and how to achieve the first while avoiding the latter. The same applies to the race we are in every day – the one where we seek to meet our company’s objectives, while the obstacles are too many to mention. Just like the runner, we have to stay on track, but for us the boundaries of the course are compliance requirements and standards of conduct that are not always clear. In this race, it is increasingly difficult to judge our own performance or determine where we stand in the field of competition. There is a lot of talk about the importance of benchmarking – comparing our performance to that of others or against established standards. Critics complain that benchmarking is often poorly done – comparing data that is calculated only because it is easy to collect and not because it measures anything meaningful, or using data that is not truly comparable. These criticisms are valid. How should we define what to measure and benchmark? How do we know that terms in a benchmarking survey mean the same thing to different respondents? Results have little value if the metrics do not help us evaluate and improve our actions. This happens if survey respondents interpret questions differently or do not organize their information in ways that allow for true comparison. These problems can be largely avoided, reducing the cost and enhancing the value of benchmarking, when participants use a business process framework that establishes a common vocabulary and standards of performance. In the arena of compliance and ethics risk management, the OCEG Principled Performance Framework™ provides that common ground. The OCEG Framework and free benchmarking process provided by OCEG enable companies to meaningfully measure and compare the effectiveness, efficiency, and responsiveness of compliance and ethics processes and controls. Just like the runner, we need to evaluate our own performance and be aware of how our competitors and peers are doing if we want to achieve our goals. Not every company strives for record-setting results every time out of the box. Sometimes our objective is as simple as improving slightly over last year’s performance. In either case, keeping our eye on the field and being able to evaluate what is going on around us is essential to success. OCEG is the only non-profit organization that provides detailed standards and guidance for integrated governance, risk management, compliance and ethics processes – developed through an open public process. Participate in OCEG’s free benchmarking surveys and obtain the OCEG Principled Performance Framework™ and other resources at www.oceg.org. carole stern switzer oceg CAROLE STERN SWITzER has served as the Executive Vice President and General Counsel of the Open Compliance and Ethics Group (OCEG) since it was formed by a multi-industry, multi-disciplinary group of business leaders in January 2003. Since that time, Carole has worked with experts in all aspects of compliance, covering a wide range of subject areas such as governance, employment, financial assurance, information privacy and more, to develop specific guidelines for policies, personnel structures, training, and evaluation of compliance systems and tools. She is a frequent author and lecturer on GRC and business ethics. 3 Business Trends Quarterly Technology Solutions. Business Strategy. http://www.oceg.org
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