I'm Alexander Rogge, and for today's Trace Compliance Minute, Jonathan Drimmer of Barrett Gold,

will share his insight into how to create a culture of compliance. Go ahead, Jonathan.

Creating a culture of compliance is critical to maintaining an effective compliance program.

Now, by culture, we mean instilling in every employee the obligation to do what's right,

regardless of who is in the room or what the law says.

It's not enough just to have compliance rules to make compliance part of the DNA to do what's right and to help others do what's right.

It's a culture that's needed. There's no one right way to create a culture of compliance, but two of the most important issues to get people to buy in is whether leaders walk the talk and the perceived procedural fairness of the company, particularly around compliance-related issues.

How do you create this? It's a holistic process.

Emphasizing and instilling values starts from recruitment.

It's woven through policies and procedures.

It runs through induction and into training as part of

compensation and performance commitments, factors into the third parties we retain, and it's audited

and it's tested like any other aspect of a program. So while there's no one right way to

ultimately create this, it does require a top-to-bottom approach focusing on leaders walking the

talk and creating actual and perceived fairness among a workforce and third parties.