Culture's Revenge (Part 2): Few Practical Solutions

Where Are the Biggest Risks in Implementation?

Rolling out a global compliance program comes with its fair share of red flags—risks, resistance, and at times, complete disinterest. These are the moments when cultural differences can make or break your initiative. The easiest way to understand these local dynamics is to speak with the local General Manager (GM) or CEO—they know why things are working in some places and failing in others. But even then, there are always surprises: for example, why Standard Operating Procedures (SOPs) work smoothly in one region, like Switzerland, but face resistance in Eastern Europe, Latin America, or Asia.

Let’s take a closer look at each step of the rollout process and pinpoint where the biggest challenges typically arise:

Program Design (Global HQ Level)

🚩 Biggest Risk: Poor design at the HQ level. If you fail to create a well-thought-out program, the project will falter. Additionally, you can expect resistance from top management if your proposal is poorly presented (using 50 slides when 5 would do). However, once you get buy-in from top leadership, it's like having an army of project managers pushing your agenda.

🚩 Another risk: Resistance or lack of interest from supporting HQ functions—legal, HR, IT—who are already swamped with other responsibilities. Don’t forget about IT; integrating software with the compliance procedures is critical for success.

✅ Solution: Involve all relevant departments early in the process, and make sure the project is presented in a clear, concise way to top management.

Local Adaptation of the Program

🚩 Biggest Risk: Resistance and lack of interest. At the local level, the biggest challenge is getting people to care about the new program. The general attitude is, "I’m busy, I don’t have time for this." Nobody likes change, and this resistance is present everywhere unless there’s a compelling reason for local teams to cooperate.

For countries like Switzerland, Germany, and Scandinavia, resistance comes from the fact that they’ve had long-established procedures that work like a Patek Philippe watch—expensive, highly detailed, and reliable. They are proud of their systems and may feel they’ve already mastered compliance.

✅ Solution: You can’t simply say, "Compliance is non-negotiable." Instead, acknowledge their good processes, but emphasize the need for global harmonization—same definitions, same concepts, same approach. Use arguments like simplification and the opportunity for them to be trendsetters in the global company.

For non-US companies, there’s often resistance when the change isn’t coming from the US. The US tends to drive compliance in global corporations, and this can cause friction when setting standards for issues like data privacy, where EU-centric rules might be required.

✅ Solution: Engage with the superiors of the US management early on to smooth this process and align expectations.

🚩 Another Risk: Lack of interest or ignorance: This is a red flag that will cause problems later. This could be due to a lack of self-confidence, a tendency to trust everything HQ says, or a deep-rooted reluctance to fully adopt formal procedures.

✅ Solution: Discuss specific individuals who will be responsible for implementation with business leaders at HQ. Form a group of attentive and cooperative individuals for pilot testing to ensure early success.

Trainings and Certifications

🚩 Biggest risk: Countries where local adaptation was weak or non-existent. If there’s little interest in adapting the program, employees won’t engage in training, ask questions, or take the process seriously.

✅ Solution: Conduct face-to-face trainings in these regions or bring in dedicated compliance experts, either external or from a successful subsidiary that acted as a pilot country. Involve these countries in pre-launch testing to force engagement.

Launch & Monitoring

🚩 Biggest Risk: Some countries may not implement the process at all—this is common in Eastern Europe, LATAM, and APAC regions.

✅ Solution: A simple confirmation that something has been implemented is not enough. You need evidence of a functioning process from day one. Monitoring should cover not just compliance but also identify mistakes, glitches, and other issues to be fixed.

Enforcement

🚩 Biggest risk: Non-compliance without consequences. If there is non-compliance and no enforcement, your entire effort could unravel.

✅ Solution: At the beginning, focus on enforcing penalties for non-compliance rather than punishing mistakes related to learning the new process. However, if the same mistake occurs two or three times, it’s no longer a mistake—it’s deliberate non-compliance. In some regions, only strong enforcement, including terminating employees, will ensure compliance is followed.

Conclusions

When rolling out a global compliance program, physical presence—or at least, direct communication via platforms like Teams or Zoom—is essential for overcoming resistance. However, this approach doesn’t need to be applied everywhere. Instead, focus on regions that show the most resistance and engagement challenges. In lower-risk areas, where things are running smoothly (the "green zones"), you can delegate tasks to others.

Key Tips for Effective Implementation:

✅ Prioritize Low-Risk Countries First: Dedicate your time and resources to low-risk countries at the beginning of the project. This will allow you to handle straightforward tasks and free up time for more complex regions later.

✅ Save Energy for High-Risk Countries: Reserve your energy for high-risk countries as the project progresses. These areas often require more direct involvement, particularly during the final stages of implementation.

✅ Identify and Monitor Time Bombs: The biggest threats often come from individuals or teams who are disengaged, inattentive, or ignoring the project. These people are like time bombs—seemingly harmless at first, but capable of derailing your project later. Map them, involve them early, and closely monitor their engagement.

✅ Handle High-Risk Countries Like Russia with Extra Attention: Some countries, like Russia, will need consistent, direct involvement at every step, from local adaptation through auditing and improving. In contrast, low-risk countries like Switzerland may only require focused attention during phases like monitoring and enforcement.

✅ Use the Corruption Perceptions Index (CPI): The CPI is a useful tool for identifying high- and low-risk countries. However, remember that the CPI applies to countries, not subsidiaries—adjust your approach accordingly for specific regions.

✅ Leverage the Visual Chart: Use a chart that highlights red, yellow, and green zones to indicate which areas demand the most attention. Red signals high-risk regions requiring direct involvement, while green indicates areas where you can delegate tasks. Remember, red doesn’t mean bad—it just means extra care is needed for success.

Well, if you are lucky and working only in Western Europe you may have countries representing this chart below :-)

(illustration of the key elements of planning based on country risk levels and implementation stages.)

By following this approach you’ll be better equipped to allocate your resources. Even if a red zone is located in a distant or hard-to-visit area, you can still dedicate virtual attention to maintain compliance. If you primarily operate in low-risk regions like the US or Western Europe, your map may look greener overall. But in high-risk areas, it’s crucial to stay involved from start to finish.

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www.kruk.ch/general-8

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