Greetings reader! Thanks for joining us for the fifth volume of the 12 Best Practices of Compliance Solutions Series.
In this series, we will address twelve of the key challenges you face, one-by-one, with best-practice advice derived from over a quarter of a century of support to global industry!
Volume 1, regarding staffing challenges, can be accessed here.
Volume 2, on getting leadership commitment, can be accessed here.
Volume 3, on the impact of acquisitions/mergers and divestitures/de-mergers, can be accessed here.
Volume 4, on ongoing compliance management, can be accessed here.
In this volume, we examine the challenge of how to roll out your compliance program and get employee engagement across your global locations.
The benefits of a global EHS compliance program are clear. However, rolling out a global compliance program, if starting from scratch, can be a lot easier said than done. There are a whole host of practical/logistical issues to address. For example:
- We often see a historical “devolved” approach to managing compliance—where corporate departments have no real control or insight on local EHS compliance efforts at their sites. In many cases, individual sites may already have their own local resources to support their compliance efforts; they may have been using a solution for years. It is likely in their own language, reliable, and gives them peace of mind—but does not give a global, regional or consistent view across all sites. The quality of services used (and how they are used) may vary enormously. Imposing a global solution on sites will inevitably result in some push-back and resistance. Change is rarely easy.
- There may be legacy contracts for services from other providers. Sites may have their own budget to fund compliance efforts.
- Local-language and cultural considerations mean that there may be resistance to adopting a corporate-wide approach. In-country EHS staff often feel they know what is required of them by law without outside interference.
- End-users and corporate/regional supervisors will need to build up trust in a new solution or approach.
- Different sites will need different levels of support in terms of training, regulatory assistance, applicability screening support, etc. This is potentially a huge undertaking.
- Sites and staff around the world will speak many different languages day to day; levels of English proficiency will vary. Unless services and support offered cater for these languages, it will present a potentially insurmountable issue.
- There could be a potential lag time when implementing a new program, leading to gaps in compliance coverage.
So, how can you roll out a program across all of your global locations as efficiently and effectively as possible?
Enhesa has worked with companies managing and implementing global EHS compliance programs for more than 25 years. Based on our experience, we would say that there are five common denominators for best-practice in implementing a global EHS compliance program:
- Lead from the top
- Involve everyone
- Speak everyone’s language
- Support, train and inform
- Choose the right tools and services
The desire and need for a global approach needs to come from the top. Without corporate buy-in and commitment, a global approach will not happen. What’s more, if corporate is paying for a global EHS program—and saving sites money—successful implementation is more likely.
Of course, a global outlook for corporate EHS regulatory compliance does not mean taking responsibility away from local site knowledge and expertise—Far from it. In general, by setting the tone, the standards and the priorities, a corporate EHS function guides, inspires and gives more weight and ownership to on-site personnel working in the field.
It can also pay to start small, piloting a solution or program on a few key sites. This will create internal champions for your global program and encourage a “pull” from other sites. Once they see and hear of the effectiveness of a solution, they will be keen to learn from and adopt a similar approach.
If I, as a plant EHS manager, feel my corporate heads are watching out for me, giving me the structures and financial support that I need to do my job, I will feel more valued and will perform better. In turn, if I support my global and regional EHS structure through measuring, calculating and reporting on my local EHS performance and challenges, I am directly inputting into the corporate strategy and directly influencing the safe-working and environmentally-conscious practices of my colleagues around the world.
The approach is also backed up by evidence from Enhesa clients, which demonstrates how different levels within an EHS management structure use our services:
- Site-level EHS staff use a facility dashboard in order to determine the laws and regulations that apply to them; to self-assess compliance against the relevant requirements and keep on top of regulatory change through alerts. This means that sites are provided with a tool that fulfills the needs of a “legal register” (and in fact goes beyond that), and therefore do not need to spend money on a local-solution. Corporate pays.
- Regional/Country-level EHS personnel use the corporate dashboard to support and assist sites, and to verify and maintain an overview of compliance status across their region.
- Corporate EHS Auditors use the Enhesa Scorecards (in Excel) to carry out site compliance/verification audits, and are able to upload the results into the compliance dashboard.
- Corporate EHS managers have a global view of their compliance status, can hone in on risk factors or specific issues at facility level and be more efficient and effective in where they choose to spend their auditing resources. This allows them to be more confident that they have knowledge and understanding of the compliance status, on an ongoing basis.
In terms of involving everyone in the company, and the need to select the right tools and services, the following are essential to help to achieve this:
- Global coverage – apply a consistent service across all of your sites
- Enable (or support) simple filtering of which laws and requirements are applicable
- Ensure that regulatory compliance information provided is clear, and has suitable guidance
- Provide tools, information and training both in English but also (and often more importantly) in the local language of the in-country users
- Make sure you have a regulatory support service provided by experts from the countries in question
- Apply a standardized, easy-to-use interface with the necessary level of details for different levels of user
- Frequent updates, with changes clearly indicated and notified
In conclusion, it is worth referring to the words of corporate EHS Directors who have experienced the successful implementation of a global compliance program:
Executive Director EHS, Power Solutions
“As with any change in any organization – there are always challenges. Some people love the change and embrace it, whereas others hate it, of course. However, through our global management system we established a need for a robust clear compliance process. We also signed up to have sites certified – so leadership and sites were aware of what certification meant and what it required – and the need for certain tools to enable aspects of this – such as compliance assurance. This created a ‘pull’ from the plants so at corporate we offered sites options and solutions. The more people that wanted a global solution the more that drove the [success of the implementation].
Now we have a uniform, robust, platform that we, and all the sites rely on. There was some resistance from regions or sites that already had something in place, but as you can see the [global EHS compliance program] spread from Power Solutions to other departments and has now become well integrated in the business.”
Senior General Manager, Environment Innovation Center, Global Manufacturing Innovation Headquarters
“As a first step, we chose to carry out pilots on two sites (China and Malaysia). Having completed the pilot, we swiftly realized the necessity of having a global EHS compliance management, so we gradually expanded the program to cover other countries and sites.
When implementing the compliance management, we told each site that we were going to implement the EHS compliance management program with budget from headquarters and asked them to participate in the program by providing them with the Enhesa Audit Scorecard and asking them to use it as a self-assessment tool. Ideally, we would have sent someone from HQ to help each site carry out their self-assessment but that was unrealistic, so we asked each site to do the self-assessment by themselves.
We informed sites that this was a corporate program, funded by HQ and with tools provided by HQ – and merely asked them to carry out the self-assessment. Fortunately, we have not had any major opposition or complaints to this approach from any of the Omron Group companies concerned.
I personally think that because we are doing this global EHS compliance management program using a corporate budget, each group company has been more receptive to the corporate governance executed by HQ.”