Compliance Online delivers policy writing masterclass

In a recent webinar, experts explained the dos and don’ts of effective policy writing.

One of the primary reasons that employees don’t understand their organisations’ policies is that they are badly written. This is according to Elizabeth de Stadler, Compliance Online subject matter expert and founding member of Novation Consulting, who was a panellist on a recent CHRO SA webinar about how to write a document people will read and act on.

“The question I want to answer this morning is, “why do so many policies lie around gathering dust?” said Elizabeth, who felt that policies often ended up in a file or folder that nobody ever opens or reads. They are hardly ever reviewed and few people in the organisation have an understanding of what the policy is, because they are badly written.

Elizabeth advised attendees that, when writing policy, the most important thing is to keep it simple, avoid complicated vocabulary and jargon, and use effective writing. This means that it must always answer the questions of who must do what, when and how.

“Remember that less is more,” said Elizabeth, adding that, in cases where policies are well-written, it is sometimes clear that they were written for an entirely different organisation. This is because the people writing policies often use templates from other organisations, which can be a big mistake.

Said Elizabeth: “Many people ask for templates upon which to base their policies and I, for one, do not believe in that approach. It often leads to bad policymaking because people are copying verbatim. I was once doing some work for one of the big universities and was reading their compliance management policy when I realised that it had been borrowed from an insurance company to the point that they didn’t even take the insurance company’s name out of the policy. It was therefore not surprising when that particular policy couldn't be implemented. It simply wasn't fit for purpose. A compliance management policy for a financial services provider shouldn’t be the same as that of the tertiary institution.”

That said, Elizabeth said it can be helpful to benchmark your policies, when looking for ideas on how other organisations have approached a particular policy. When doing this, however, Elizabeth said to limit your search to similar companies and only use their policies as inspiration instead of taking a copy-and-paste approach.

Start with the ‘why’

Referring to her favourite author, Simon Sinek, Elizabeth said that it was vital to start with the ‘why’ when drafting policies. Because, once the intended purpose and behaviours are understood, it becomes easier to write an effective policy.

Said Elizabeth: “Here is some wording from our own policy: ‘One of the important things for a consultancy is that our employees must be very careful when they give away our intellectual property.’ So the way we explain it to them is by describing how each business has their secret sauce and skills that make them unique, which their clients pay for. ‘This knowledge and these skills took years to develop. If we give them away for free our business will fail.’ This is another way of explaining a consequence. Because if the business fails, employees will not have a job.”

Elizabeth said they had found this statement to be far more effective than statements similar to the following: ‘If you disclose our confidential information without our written permission you will be faced with disciplinary action.’ This kind of statement does not motivate people into action.

“Our policy around the same issue helps our employees understand the ‘why’,” she said.

Involve the right people

A policy is a set of principles that sets out a framework of how you are going to meet a particular policy objective, such as the POPI Act, for example. It should create principles that guide employees through each individual. That is why it is important for the author to ensure that they are not writing for themselves. The policy must meet the needs of the intended audience – not those of the compliance officer or the HR department.

“Sometimes you are writing a policy for a regulator and thus need to take that ‘user’ into account,” said Elizabeth, adding that the biggest factor determining policy success or failure often depends on whether the right people were involved in the drafting process or not.

Policy passport

Webinar attendees also heard from Trinette Peterson, Ad Ingram national QA head of distribution, who said that, because they operate in a heavily regulated environment, their employees have to be tested on their policies.

“We produce medication that has to be ingested by our customers, so we have strict guidelines and policies that we need to adhere to. We also need to write these policies and standard operating procedures so that our employees know what to do, how to do it and when to do it by,” said Trinette.

In their environment, she said, they have to save documentation for up to seven years, and documentation surrounding a product must be kept for up to a year after that product has expired. Prior to using Policy Passport, a platform that electronically alerts employees to the documents that they need to read, everything was done manually and Adcock Ingram was going through piles of paper.

“When we had to give training, we would have to make copies of all our policies, stamp them, hand them out, give people tests, create classrooms, explain it to staff. And if you were a fast reader who could go through the policy quickly you had to wait for people to catch up with you. Then you had to write a test and somebody had to mark it. And then gather all that information.”

Now that Policy Passport has automated that entire process, Trinette said the company was now able to test people very easily on whether they understand a policy. In cases where many employees were performing poorly in those tests, it alerted them to the problem that perhaps the policy had not been written correctly.

Overall, it was an insightful webinar from which attendees left understanding the difference between a good policy and a bad one, while also understanding how to measure the impact of a policy by ensuring that people understand it.