A week ago, I initiated a highly scientific research poll (ok maybe not that scientific) aiming to bring a touch of humor to the often sober world of compliance.
A phenomenon that has been increasingly raising eyebrows and sparking debates among the compliance community is the practice of “tick-the box compliance”, or what most of us refer to as “window dressing.”
In Part one of a two-part series, I delve into the nuances of this intriguing concept, exploring its implications and shedding light on the creative labels our compliance community has coined for it. Part 2 is your comprehensive guide to recognizing telltale warning signs of window-dressing.
Now, before you envision yourself following Martha Stewart instructions and adorning your living space with exquisite curtains matching with your indoor plants, let’s clarify that this type of decoration doesn’t involve aesthetics but financial matters. In fact, we owe the term “window dressing” to the world of accountancy, where it’s defined as “a technique used by companies and financial managers to manipulate financial statements and reports to show more favorable results for a period.” Window-dressing is a dishonest business practice, and is usually done to mislead investors.
In the world of compliance, this can be likened to judging whether a company is genuinely implementing its compliance program, or if it’s merely flooding the scene with superficial communication about its values and ethics, fluff that lacks any substantial foundation.
The poll’s specific goal was to craft a catchy term to describe a company’s compliance program that focuses on minor misconduct while conveniently overlooking more profitable agreements, creating the illusion of a robust compliance effort. A situation analogous to catching small fish while allowing the big whales to freely slip through.
The responses poured in from around the world, revealing a collective sentiment that speaks volumes about this aspect of corporate citizenship.
Let’s take a closer look at the poll results, and the creative terms proposed: