Compliance Conversations: How do you determine a policy is understood?

Posted by Craig Thornton

In this video series, Peter Rogers from Mango, discusses what a policy should contain.

He discusses, with compliance consultants from around the world, how to make sure policies are understood and effective. 

The consultants give us insights into these subjects with some handy tips on ensuring that your policies are clear and concise.

This is #3 in a series 4 compliance conversations about policies.

The question we answer in this conversation is "What is the best way to determine policies are understood?"

Check out the video here:

 

What is the Best Way to Determine That Your Policies are Understood?

 
Richard, Smart Quality, United Kingdom

You've got to really test the understanding of the policy.

It's all very well to have them displayed, communicated and given out, but the best way to determine that they're understood, is to actually ask for feedback and ask the questions of the employee: "What does this mean to you?"

It's management by walking around.

One way of doing it, is to actually go to the employees and ask them what their understanding is, and test it in the field.

You can't assume that they'll understand because you've sent it to them.

Obviously, we can do some e-learning, and questions and answers and scores around that, but the best way to do it is for them to put it in their own words back to you.

Rather than reading it out, some companies have actually, in the past had employees remember and say it off by heart, but that's not very good when you don't have a clue what it means.

Asking them to tell you what it means in a different set of words is really one way to do it.

 Gary, QSM, Australia

This is the hardest part, it’s the most challenging part for most businesses.

Obviously, you do the very basic stuff like checking for understanding of the policy at the time of induction but that in itself, is just the initial first check.

What's required is the ongoing engagement and reinforcement with people at all levels throughout the business over an extended period of time.

It's about matching the day-to-day behaviours that are demonstrated by people in the business against the requirements of that policy.

If the management or the supervisors, team leaders, other people in the business, see behaviours within the business that are not in keeping with the policy, then it's important that people act on that.

Because a policy that is sitting on a wall somewhere - it may be the best written policy that ever existed - but if it's actually not enforced on a day to day basis, then the words mean nothing, and people within the business will actually view it and see it that way.

Mark, Business Basics, Australia

The best way to work out if they're understood would be to actually talk to the people in the business and find out whether their behaviours, the way they talk or the way they communicate and what they hold important matches with what's in the policy.

There's no point saying in the policy ‘we're going to uphold the greatest environmental standards in the world’ and then when you talk to people in the business they say ‘Ah we don't even recycle!’

To determine if policies are effective and understood, you've got to engage with the people in the business and see whether they follow what's in it, and whether they understand it.

If they don't understand what's in it, and it doesn't match what the beliefs are, the policy is just a worthless piece of paper that hangs on the wall.

Nicholas, SRM, South Africa

For me, one of the critical elements that we're driving with a lot of our clients at the moment, is consultation and participation of workers.

Now I know that's incorporated into the ISO 45001 standard but it's nonetheless important to anything else that we do within our organisation.

First off, workers or their representative should be involved in the development of the policy.  Once the policy is developed, and workers then having sight of it, it should be nothing new.

In terms of it being understood, everybody and all their representatives, should be involved in the development of the policy.

Obviously, it's approved by management, and then it should be cascaded through the organisation, through a variety of different training mechanisms, be it induction or employee onboarding, or contract onboarding.

To ensure that it's understood, because it's one of those vision documents that's important to an organisation, when I'm auditing, I'll go around, and I'll ask work as a whole lot of questions:

    • Do you have a policy?
    • Where will I find it?
    • Can you tell me any of the key things that you understand about a policy?

If the worker can speak to me around some of those high-level values that the organisation has committed to, I will then have a sense that they have participated in it, or it's been understood by them.

They have to understand the key values of that policy, for me to determine that its been understood.

Michael, Momentum Safety and Ergonomics, Australia

This is going to be like many of our other education training activities that we go through. It's really going to depend on the who, and to some extent, the what, that you're trying to teach people.

Obviously, we could have our policies that we want our employees to really understand, somewhere in an induction document.

There might be the opportunity for people to put snippets into introductory videos, then moving forward, looking at building them into training topics.

You might, for example, have manual handling and ergonomics, and build some of your policy elements into that training, just so that they're reinforced in the other training courses that we do.

Then how you deliver that that's going to depend on the topic.

It may be online platforms versus face to face toolbox talks, and all that will depend more on the worker and the environment that you're working in.

Chris, FQM, United Kingdom

I think often it depends upon the organisation.

The important thing to recognize with a policy, is that it plays absolutely no purpose, unless you can identify that your audience have understood it, and recognize what the expectations are.

There are a multitude of ways of doing it:

      • portraying it on noticeboards
      • sending it
      • giving it in inductions
      • having it in an electronic system
      • putting it in a document pack.

There are a multitude of different ways that will work.

But none of them actually will give you any kind of guarantee that it's been read and understood, and people know what's expected of them.

Always go back to the audit process.

I believe one of the best ways to do internal auditing is not looking at a quality policy. That plays no purpose. Because you have no way of knowing if that quality policy is effective or not, and known by people.

Therefore, using your audit process allows you to go to people and speak directly to them and adjust your questions in such a way that:

    1. Do they understand the quality policy?
    2. Do they understand what the purpose of it is?
    3. What they have to do about it?
Peter, Mango, New Zealand

Another one is site observations. Sitting back and observing, are they working in a way which is in line with the policy?

Not everything will be perfect, but you can soon see if someone is keeping their area tidy and you can say that they are applying themselves to what the policies intent is, there might be a line that says ‘we will have a clean and healthy workplace’.

Well, if you've gone out to see someone and they're sweeping, they're tiding, they take pride in their work, then you can say they're probably a tidy person, but they are in line with the policy versus you go down the road and you see a lot of people doing the complete opposite, then you know that the policies intent has not been communicated.

It's actually a management problem, the bridge from who's my audience to what is the document, saying, have I got a disconnect?

 Jodie, Penarth Management, United Kingdom

Talk to people, ask them what they know, and see what's happening out in the real world, that will tell you if those policies have been understood, and if they are working.

John, Many Caps, New Zealand

Making sure your policy is understood is to start with the people who are going to be involved in helping create the policy. If you bring them in, before you lock it in, so they are part of that conversation, that's going to help.

Then it's about having conversations with the team.

Rather than just take it out, stick it on the wall and walk away, we have a policy, get your team together and have a chat about this is what it is this is what we mean by these words, and this is what we're looking for, and have a conversation and take questions and take feedback and if need be, tweak the policy again, so that it's easier for the people.

 Andrew, IRM Systems, Australia

Really just by interviewing people, talking to people.

If you’re the internal compliance person, talk to people both in a formal process but also informally as well, and this is the best way of detecting whether there’s some awareness and understanding of the purpose of the policy.

I don't think people need to be able to recite the policy word for word, that's not important, as long as they broadly understand what the organisational expectations are under the safety, quality or environment policy.

Sean, Kaizen Consulting, New Zealand

In terms of communication of the policies, the best way is to cover that during induction, where you get the employees to read the policy, but also have a questionnaire. It's no different with other competencies that you want to confirm whether the person has understood.

If you take a few critical bullet points out of that policy and create an assessment from that, and then you can have an assessment during your induction or as a refresher every 12 or 24 months, saying:

    • What does the company stand for when it comes down to reporting of accidents? Or,
    • What is our commitment to continuous improvement and how we do it?

Or, if it's a quality issue in terms of, customer feedbacks,

    • What are the company standards in terms of company and customer feedback and satisfaction?

Have open questions or in some specific industries where the literacy is not as high, it could be multiple choices, some level of engagement from the staff to actually demonstrate their competency and understanding of those policies in a written form.

 
Takeaways
  1. Test the understanding with staff i.e.
    1. Do you understand the policy?
    2. What does the policy mean to you?
    3. What are the key things you understand about the policy?
    4. What are your responsibilities within this policy?
  2. Carry out site observations to see if the workers are complying with what the policy states.

Tags: Quality Management, Compliance, Compliance Conversations