Promoting a culture of compliance

Last week, several FHI 360 staff joined other leaders of nongovernmental organizations (NGOs) at the InsideNGO Annual Conference in Washington, DC, to share cutting-edge strategies and proven practices. Sean Temeemi, FHI 360’s Chief Compliance Officer and presenter at the conference, offered his thoughts on FHI 360’s approach to global compliance.

What is meant by global compliance? Why is it so important?

Global compliance covers global operations. Like a lot of large, international organizations, FHI 360 works in a complex regulatory world. Complying with rules and regulations is challenging but vital to our credibility and effectiveness. This is an issue that is important to our funders, our Board of Directors and our senior management.

Why is this topic so timely?

We are responding to the needs of funders, who have increased their scrutiny of organizations. A lot of organizations are now developing compliance programs. Just about every day, you read about issues involving fraud and embezzlement. Ten years ago, you would have heard less about it. Today, there is a push to put resources into compliance. It is definitely a trend in the industry and is a priority at FHI 360.

What is the most important lesson you have learned through FHI 360’s work in global compliance?

It is critical to have the support of your organization’s management. FHI 360 has been successful because we have support from our management team and Board of Directors. We have compliance staff located around the world, and we are also represented on the Executive Team.

What is FHI 360’s approach to compliance? What makes it unique?

We focus on the proactive and preventive and have developed compliance-related training on topics such as conflict of interest, bribery and the Foreign Corrupt Practices Act. Our Office of Compliance and Internal Audit has established an independent anonymous hotline, a whistle-blower website and an internal portal where FHI 360 staff can access a range of tools and resources.

Our approach is collaborative, from planning to execution. For example, we don’t just do an audit and leave. We discuss the purpose of our recommendations and help with the follow up. This way we make audits learning experiences and opportunities for improvement.

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