Client challenge:

The energy to drive consistency

A large utility company was powered by the desire to build a more robust compliance program, with the goal of driving consistency in compliance management across the organization. There was a compliance program in place, but the company’s many business units were isolated, acting largely independently, and compliance activities were decentralized for the most part. The company established a new C-suite level position, Chief Ethics and Compliance Officer, to oversee compliance company-wide and create a comprehensive ethics and compliance program.

Our approach:

Shining a light on compliance with maturity milestones, scores and controls

When company leaders learned that PwC had previously helped other organizations to design or mature their enterprise compliance functions, they asked for our assistance in designing a program that would be tailored and customized to their organization. We had worked collaboratively together many times and built a level of trust that set the stage for a productive compliance conversation. How do you determine if the right leadership is in place? What kinds of training programs should be developed? How do you create a process for documenting compliance performance? PwC’s Forensics team, professionals from our Risk Assurance practice, as well as professionals with deep utility industry experience worked closely with the new Chief Ethics and Compliance Officer and leaders from across the business units to build a model and create a governance structure that would operationalize the company’s policies and procedures.

With our established proprietary model as a blueprint, our teams collaborated with company stakeholders to customize the model to reflect the organization’s unique culture and communication style and to encourage broad engagement. The resulting framework has a number of innovative features. These include refreshing the seven elements traditionally associated with compliance models—from governance through remedial actions; and a maturity score to help employees and managers across business units see where they are on the compliance journey, with milestones to mark achievements along the way. Because the company wanted a forward-looking approach, the CMM also includes an element around rigorous compliance controls, which can help the company to demonstrate that it has the right skills, processes and approaches in place to meet both internal and external compliance requirements.

Impact:

A powerful commitment to compliance

The company has cultivated a culture of compliance that sets an enhanced standard for the organization through this enterprise-wide initiative. The model was designed to be standardized, transparent and user-friendly. A single vision and transparency around compliance spark collaboration across business units. Designed to encourage achievement of maturity levels over time, the model provides a rigorous and realistic framework for compliance. Praise for the model and a commitment to service and safety for customers have motivated the company to share the model -- which is both highly replicable and customizable -- openly with industry peers. 

To learn more about how implementing a robust, customized CMM can drive consistency across your company, visit www.pwc.com/us/forensics.