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HCCA AK REGIONAL COMPLIANCE CONFERENCE FEBRUARY 27, 2014
Barbara Harmon
Compliance & QA Lead
Alyeska Pipeline Service Co.
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• Alaskan company that maintains and operates the 800 mile long Trans Alaska Pipeline System on behalf of five owner companies
• 800 employees; 1,200 contractors
• ~ 750 regulatory commitments; 22 agencies (federal, state, local) with jurisdiction
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� Program design and implementation
� Two Approaches to Program Maintenance
�Rational - Classical Approach
�Creative - Romantic Approach
� Quality and Balance
Your company has invested time and resources into designing and implementing a compliance & ethics program that incorporates the 7 elements:
1. Appointed a Compliance & Ethics Officer, a Compliance Committee; the Board has been properly informed
2. Written a code of conduct and compliance and ethics policies and procedures
3. Rolled out basic compliance and ethics training
4. Established periodic monitoring and auditing schedules
5. Taken steps to prevent and detect criminal conduct
6. Established methods to raise concerns
7. Have methods to investigate and resolve concerns
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PROGRAM MAINTENANCE
Two approaches to compliance management:
The Compliance Classic focuses on the details
and the inner workings of the compliance and
ethics program.
The Compliance Romantic focuses on the big
picture utilizing creativity and intuition.
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Classic ~
Romantic ~
Which approach do you take?
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~ Which approach do your executives/board take?
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ACHIEVE PEACE OF MIND(with regards to company compliance & ethics program)
Compliance Maintenance is best achieved by embracing both the rational and the intuitive
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� PERFORMANCE MONITORING = utilize your “classical” rational management techniques and analysis
� TRAINING & COMMUNICATION = use “romantic” creativity and intuition/ soft skills to create a culture, and ensure people know expectations for business behavior
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Think of it like
SCHEDULED MAINTENANCE
� Key Metrics Tied to the Seven Elements1. Program Management/Oversight
2. Policies & Procedures
3. Training & Communication
4. Monitoring & Reporting
5. Enforcement
6. Concerns Reporting
7. Response & Resolution
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1. Program Management/Oversight -
� # Regulatory Agency Concerns/Enforcement Notifications
� # Board Presentations/ Executive Reviews and/or
Compliance Committee Meetings
2. Policies & Procedures -� % of Methods of Compliance Documents That Are Current
3. Training & Communication -� % Regulatory Training Complete
� % Compliance & Ethics Training Complete
� # Newsletters or Messages from the CEO/President
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4. Monitoring & Reporting -� # Risk Assessments, Internal Audits completed
� # Compliance Performance Reports Submitted to Board/
Executives per Year
� % of Required Reporting to Regulatory Agencies Complete
5. Enforcement-� % Completion of All New Hire Background Checks &
Promotions Internal Background Reviews
� # Employee Recognitions
� # (and type) of Formal Disciplinary Actions
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6. Employee Concerns -� # Employee Concerns/ Hotline Resolution Actions
� % of Investigations Substantiated
7. Response & Resolution -� % Compliance-related Corrective Action Closure
Comments Reviewed by Compliance Manager to Ensure
Appropriate Resolution
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Ho-Hum Trending
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2008 2009 2010 2011
50 30 40 50
# of Regulatory Agency Unsat. / Warnings per Year
14%
8%9%
7%
0%
2%
4%
6%
8%
10%
12%
14%
16%
0
100
200
300
400
500
600
700
800
2008 2009 2010 2011
Total # Regulatory Agency Inspections &
Surveillances per Year
Satisfactory Unsat./Warning % Unsat./Warning
Ho-Hum Trending
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Improved Trending
OSHA Compliance 2010 2011
Total OSHA Recordable Incident Rate at Our Company 0.23 0.26
Days Away From Work Cases (DAFWC) 0.00 0.04
Our Company vs.
National Pipeline Industry
Incident Rates
National PL
Industry Average
2010
Our
Company
2010
Our
Company
2011
Total OSHA Recordable Incident
Rate 2.50 0.23 0.26
Days Away From Work Cases
(DAFWC)0.90 0.00 0.04
See Bureau of Labor Statistics www.bls.gov/iag/tgs/iag_index_alpha.htm
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Ho-Hum Trending
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2008 2009 2010 2011
100 110 100 150
# of Employee Concerns per Year
2008 2009 2010 2011
Core 35 40 20 10
Non-Core 60 60 60 90
Consultation 5 10 20 50
Substantiation Rate 15% 25% 60% 70%
Core = a concern related to safety, system integrity, or HIRD
# of Employee Concerns per Year
MANAGE YOURSELF
� Five Tools of Wisdom
INSPIRE OTHERS
� Using Compliance Violation Headlines to Spice Up Your Board Meeting Reports
� Ethical Dilemma Videos
� Compliance & Ethics Week
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Five Tools of Wisdom for the Modern Compliance Professional
1. There is a Way Through Every Block
• Remember there’s a solution for everything
• Utilize the wisdom of others
• Shift your thinking. How can you look at it differently?
• What do I have control over? Focus on the aspects of
the situation that you can influence or control.
• Take a personal break ~ Do something else for a while.
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Five Tools of Wisdom for the Modern Compliance Professional
2. Understand Through Compassion or You
Will Misunderstand the Circumstances
• Get the facts
• In this application, ‘compassion’ doesn’t mean pleasing
the other person and their agenda. It does mean
listening openly and ferreting out the neutral reality of
the situation
• Avoid over-reacting or under-reacting – appropriate
level of response
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Five Tools of Wisdom for the Modern Compliance Professional
3. When a Situation Presses Upon You~ Start ~ and the Pressure Will be Off
• Be brave. Step forward and start working on the issue.
• The longer we churn an issue, the bigger and more
burdensome it becomes.
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Five Tools of Wisdom for the Modern Compliance Professional
4. Embody the Highest Values, and the Path Forward Will be Made Clear
• Remember your Code of Conduct, as well as your own
sense of principles and ethics.
• Pressure test everything against the fundamental
values of the organization. Trust the solutions will
come forward.
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Five Tools of Wisdom for the Modern Compliance Professional
5. Recognize the Other Person is You(Find Commonality)
• Put yourself into the other person’s situation and
perspective. Practice seeing what you have in
common. Listen.
• When we polarize with others and focus on our
differences rather than our commonalities, we can
block the solution from coming forward.
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EXAMPLES OF CREATIVE WAYS TO
COMMUNICATE A CULTURE OF COMPLIANCE
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Use
Compliance
Violation
Headlines to
Spice Up
Your Next
Board
Meeting
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A Compliance & Ethics “(ACE) Soap Fable” Storyboard
1. Title, IntroOur Company Presents…AAAA CCCCompliance & EEEEthicsACE Soap Fables
2. DISCLAIMER:The scenarios depicted in this video
are purely fictional and meant only for educational
purposes. Persons in this video are amateur
wanna-be actors and by no means actually behave
this way in real life, nor support the life-style
choices depicted.
3. Video employee discussions posing ethical
dilemma
4. Dramatic organ music swells as the Narrator
reads a couple of silly soap opera questions (e.g.
“Should Chris have gotten more than 2 hours of
sleep before reporting to work?”; “Will Ginger’s
sister’s cousin’s brother’s best friend lose his
license?” …Stayed tuned for the next exciting
episode of ACE Soap Fables…But first, a word from
our Sponsors…
5. Office Interview with Executive or Manager
accountable for that business area citing from the
Code of Conduct what behaviors are expected.
6. And the Moral of the Story is…
Key Point
(cue organ music. Exit slide: Stayed tuned for the
next exciting episode of ACE Soap Fables..)
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When is it inappropriate
to don your company
logo-wear in
public? Review our
Political Activities policy
Are you aware of our
policies with regards to
data and images
generated or stored on
company IT
equipment?
Do you understand what
a conflict of interest is?
Review expectations for
avoiding any appearance
of conducting company
business for personal
gain
What is our policy with
regards to protecting
confidentiality?. Review
when care should be taken
in communicating
confidential employee
information
What should you do if a
vendor or person seeking
to do business with our
company offers you a gift
or entertainment?
Did you know that it’s illegal
for the general public to
possess eagle
feathers? Review our
Environmental Protection
policies regarding reporting
dead or injured protected
species.
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These videos use humor and melodrama to examine a number of
compliance and ethics issues that our employees may face. Each vignette
will help employees to understand how to apply our Code of Conduct to
their business actions and decisions.”
A Compliance & Ethics “(ACE) Soap Fables”
“Our employees and contractors are expected to conduct business in a
manner that conforms to the highest ethical and legal principles.
“If you have had too much too much to drink
and only a couple of hours of sleep - you may
still be legally under the influence of alcohol.
Should you report to work? Watch this
video to review Code of Conduct
expectations to provide a safe workplace
that is drug and alcohol free.”
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Video Example
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Compliance and
Ethics Week
Examples
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Quality can be recognized, but not defined
� What makes a mechanic “good” ?
� What makes a program “good”?
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Achieving inner peace:
Nurturing the right maintenance strategy to
ensure sustainability
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Monitor PerformanceManage Yourself
1. There is a Way Through Every Block
2. Understand Through Compassion or You Will
Misunderstand the Circumstances
3. When a Situation Presses Upon You ~ Start ~ and the
Pressure Will be Off
4. Embody the Highest Values, and the Path Forward Will
be Made Clear
5. Recognize the Other Person is You (Find Commonality)
Inspire Others
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Everybody…(to the tune of “This Land is Your Land”)
Compliance and Ethics ~ It can get crazy
If you over-focus ~ or get too lazy
Monitor performance
Nurture self and others
Seek a ~ balance to set you free
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