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A CULTURE OF COMPLIANCE
Compliance is everybody's business, says Elizabeth Baldwin.

As readers of ProTips may recall, I've also been a regular contributor to the NWFA's Hardwood Floors Magazine for the past six-plus years, writing on – take a wild guess – green issues. The NWFA recently took HFM inhouse and the previous publisher has rebranded their publication as "Wood Floor Business". Because Metropolitan's goal is to help the industry as a whole, I'll be continuing on later this year as a blogger with the HFM on the NWFA site, but I've also told WFB to keep my old content up. (Actually quite a bit of material will appear on both sites.) My final regular post with the WFB group was an index of all the columns I've posted in the past 6 years. Should you want a one stop archive for your records, find it here. I asked Metropolitan if I could use a slightly modified version of my 'sign off' for a ProTips post, as I think the ProTips audience might appreciate it as well. I've entitled it "A Culture of Compliance".

The post developed as I began the process of wrapping things up with WFB. Naturally I had to thank a lot of people and of course the first thank you had to go to Metro for supporting my work on the blog. That got me thinking about just what it means for a corporation to do that. Frankly, I don't think every company would say "sure, go out and educate all our competitors!" But it is right there in my job description:

Industry Support. Metropolitan believes that compliance with all applicable regulations should be routinely conducted by all members of the wood trade industry. Metropolitan therefore permits, and even encourages, the ECO to participate in or to lead appropriate industry education and training, sharing resources and concepts while utilizing reasonable discretion in terms of information that should be considered truly confidential or unique to Metropolitan.

Why would they take that position? Beyond being good corporate citizens, there are practical reasons. Aren't we all better off if everyone in the industry was on the same page regarding the use of "compliant" vs. "certified?" If everyone recognized that HDF is a marketing term not a product? If everyone made a distinction between content and emissions? It's good when the industry is on the same page. And the products we sell are certainly more competitive against all the competing floor products out there if we don't taint our industry with bad media or misrepresentation, right? Plus sharing information means that you get ideas, too. I've definitely benefited from talking with other professionals and appreciate all the help they give to me.

Much as I would like to take the credit for this mindset, I'm not the cause of Metropolitan's attitude — I'm the result. The owners had an unwavering commitment to 'doing it right' long before I was appointed ECO in 2008. It's part of the corporate culture, integrated into everything they do.

Now maybe you want your business to have a greater focus on compliance but don't think you need (or can't afford) a fulltime ECO. That's ok — you can still have a corporate culture of compliance. You just have to work to develop it both in your procedures and your people.

Start with simple things. Set up a checklist of things you want to confirm before working with a new supplier that includes not just the usual (price, size, or shipping time), but CARB and Lacey issues. Train your salesmen to use the right vocabulary and not oversell or misrepresent through ignorant enthusiasm. Review your marketing material for correct language and proper logo use.

Be realistic about what you can do. Don't write SOPs saying you'll do X if you don't have the time and money to really do X. Develop systems that you can blend into what you are already doing rather try to impose something artificial outside your existing culture. As needed, do it in bitesized chunks, step by step, and don't stop moving forward. Most importantly, don't try to do it alone. Don't just have one person doing compliance or isolate it to just the buyers or just marketing or whoever. It's got to be part of the entire package.

How do I know green compliance has penetrated every level of Metropolitan? Because our warehouse managers call me up to confirm before shipping a pallet to California that doesn't have a CARB label on it. (They keep their eyes open because they know it's important.) Because our spec reps confidently discusses 1350 vs. NAUF without blinking. (They understand that emissions vs. content makes a difference.) Because after reviewing shipping documents, one of our buyers sends a note, "I noticed a new species on the Lacey entry, did you sign off on this as OK?" (They are sensitive to changes and check to be sure they are ok rather than accepting blindly.) Because our amazing CSR team won't generalize even when it's easier; they double check daily with me or others to make sure they are providing the right info, SKU by SKU. (They know that the details matter.) Because we will tests products even when we know they will pass; we rewrote website descriptions for greater accuracy even if it wasn't as marketing friendly; I get called in at the start of negotiations, not the end, and ownership won't buy unless every compliance requirement is checked off. Compliance has become an integral part of everyone's job, so I don't have to do it alone.
And that's what it takes for any company (regardless of size, type and market position) to succeed; embed compliance into the culture rather than try to put on any one set of shoulders. I think that's also true for the industry. If we all adopt a shared obligation to create a culture of compliance that spans the whole sector, then we'll all be stronger and more capable of dealing with the real challenges we face.