How MHA helped a global diagnostics organisation adopt a single effective compliance programme

Introduction

Our client is a global life sciences organisation specialising in diagnostics that has experienced rapid growth, both organic and inorganic who acquired a competitor and chose to run the new business at arm’s length for a period to fully assess all the operational needs.

What was the challenge?

Following the acquisition of a competitor diagnostics company, our client chose not to merge the two businesses. However, after operating independently for a couple of years, a strategic decision was made to merge the two entities. As part of the process, our client also appointed a new chief compliance officer (CCO) to establish a comprehensive compliance program from scratch that the newly merged companies could adopt.

The task of creating a new compliance program posed a significant challenge for our client. However, an additional layer of complexity arose from the need to successfully and efficiently integrate the distinct cultures of the two businesses to achieve a win-win solution that combined the best elements of both companies.

What was our approach and solution?

To help soften the integration and adoption of a new compliance program, we assisted the new CCO with the development of a compliance program by establishing a framework of guiding principles that employees and stakeholders should follow to ensure ethical behaviour and compliance with laws and regulations; the overall approach was non-prescriptive to allow a degree of flexibility around the core principles.

Once the new guidelines had been implemented, initially there was some resistance to change by the employees. To mitigate this resistance and to help staff understand the compliance program better, we implemented various change management strategies, including the following:

1. Phased dissemination of briefing documents: we developed informative materials that were gradually shared with both the existing business and the newly integrated entity. This approach ensured a steady flow of information and allowed employees to absorb the content at their own pace.
2. Soft approach to change: Instead of overwhelming employees with a massive new policy document, we implemented multiple touch points, daily reminders, collaborative initiatives and a campaign-like approach. This gentle method helped employees gain a deeper understanding and adaptation to the program.
3. Stakeholder involvement: For the employees to adopt the program, it was important that there was also stakeholder adoption as well. By actively involving key stakeholders and soliciting their support for the program, our client was able to create a culture that fostered a sense of ownership and commitment to the compliance program throughout the organization.
4. Psychological approach to change: Due to the risks around a lot of change at once, we employed a psychological approach to reshape how employees perceived compliance. By addressing mindsets and beliefs, we helped to positively influence behaviours and attitudes towards compliance within the organization.
5. Establishing a culture of compliance: We identified at an early stage that both client companies had weak compliance-oriented cultures, so we made an extra effort to instill a strong culture of compliance. This involved promoting and prioritizing ethical conduct, integrity and adherence to the established principles of effective compliance that underpinned all the work.

How did we make an impact?

The new programme of compliance was accepted and embraced in a short period of time. This resulted in a merged organization that now sees compliance as an integral part of their business, rather than an encumbrance and a resource that can be used to make sure they are making the right decisions when faced with difficult decisions and situations. In addition, the success of the programme prompted our client's headquarters to take on the same principle-based compliance approach to a global level and implement it across all jurisdictions where they had offices.