Barriers to an effective compliance culture

In Modules 1 and 2, you explored how hierarchy and structures may impact compliance, as well as how the compliance function needs to fit into a particular organisation's existing structure. This small group discussion allows you to build on your takeaways so far by analysing how compliance culture is impacted by the CEO and senior management. You will also discuss how this could produce limitations for compliance.

A positive perception of compliance within an organisation is a critical driver for ensuring compliance best practice. One example of a company that has failed to acknowledge this is Uber. Uber is currently facing stricter regulations that pose a threat to its profitability after the CEO failed to comply with the city of London's employee regulations. The effect of compliance is an aspect that Uber either did not realise or chose to ignore by not accurately registering its drivers.

Read the following articles on Uber's regulatory infringements:

https://www.vox.com/new-money/2017/5/5/15556044/uber-greyball-explained After reading the articles, discuss with your peers the state of Uber's compliance culture and how their regard for compliance has affected the organisation. Consider the following questions to guide your discussion:

What other behavioural or organisational elements may have contributed to Uber's regulatory infringements? What kind of limitations would compliance officers face in this kind of compliance culture? Are there any barriers to an effective compliance culture within your own organisation? How could this be resolved?