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From Values to Action: Building a Culture of Compliance

October 31, 2023

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Michael Woliver

Director of Ethics and Compliance
Catholic Medical Mission Board


Sarah Le Pape

Senior Manager, Marketing & Communications, IQTS, France

Join us as we explore how CMMB (Catholic Medical Mission Board), an international, faith-based NGO, worked with Humentum on a compliance assessment. Michael Woliver, Director of Ethics and Compliance, shares the collaborative nature of the consultancy, its lasting impact on CMMB’s operations, and why every nonprofit should prioritize an organizational review.

Inspired by its century-strong Catholic heritage and global health focus, CMMB has a unique perspective. Learn more about CMMB below.

When you initially decided to submit an RFP (Request for Proposal) for a compliance assessment, what problem were you looking to solve?

CMMB is a values-driven organization, and among our core values is accountability. It is central to who we are and what we do. So, it wasn’t necessarily that there was a problem to be solved, but that if there were underlying issues, we wanted to identify and address them appropriately.

Also, like many organizations, we were going through a period of operational change—both in staffing and workplace practices. We had a new CEO, who felt there were some areas of the organization that should be more fully assessed. We wanted to ensure that we were fully adhering to sector standards and applying best practices. And it was 2021, so we were navigating the transition from in-person to remote work. If we were to commit to going fully remote, we needed to understand what documentation we had in place for the various processes to continue operations and reduce any risks. We started asking the question, “If someone wins the lottery and then leaves the next day, will anybody know how to pick up where they left off?”

We knew some of what we needed to do and document regarding policies and practices, but what else would it take for us to fully realize our accountability value. The need to help us think through and inspect all aspects of the organization for potential improvements led us to put out an RFP.

Why did CMMB choose Humentum for the compliance assessment of its policy framework?

We had a lot of candidates, and I was surprised at how many different groups could provide this type of assessment. But fundamentally, Humentum’s proposal highlighted its wealth of expertise and network in our field, which was the deciding factor. It was a tight group—but when we were looking at the total value for the money and for the individuals’ insights into nonprofit work, Humentum was the best fit.

Could you share a bit about the process and CMMB’s experience during this consultancy?

The Humentum team included staff members and consultants, but they all knew each other and had previously worked together. Knowing these individuals understood each other’s strengths and weaknesses and could play to those was nice. They knew their swim lanes well, where some intersections were, and where they should be handing off to their colleagues.

We started by understanding their expertise, and on the CMMB side, we had a very cross-functional group, too. Once we got a couple of meetings in, the team understood where we were as an organization and could begin their probing questions. From the beginning, we felt like we were in good hands.

One of the massive benefits is that I've stayed in communication with some of the consultants. It has been super helpful to ask questions, bounce ideas off them, or even chat through some issues. I've really appreciated that they didn't just see this as a one-off project and move on. Through long-term relationships, their goal is to improve the sector in any way they can to help organizations achieve their missions.

The objective was to identify gaps and weaknesses within the policy framework to improve operations and reduce risk. One year later, was this achieved?

As an organization, we have used the final report in two major ways by splitting our actions by risk category – high, medium, and low. First, we immediately addressed the high risks we faced as an organization; we spent seven months tackling those and implementing processes or controls to mitigate the risks. In terms of the high-risk areas we identified, we feel comfortable with where we are as an organization while following the recommendations from the consultants.

But that doesn’t mean we are done and dusted. There are areas we must continue working on as we build out those guardrails and controls and communicate why we need to focus on these facets of the organization. But then, looking at the medium and low risks and the mitigations they provided for these areas allowed us to put together a three-year compliance plan.

The final report served as a road map for the organization. We recognize that this is a journey. It's not just some switch you can flip and say, "Now we're completely compliant and operating as per best practices." It's striving to build a compliant and ethical culture, and it keeps us curious and focused. From my perspective as an ethics and compliance officer, our primary objective was completed as a team. 

Was there one recommendation you felt was most impactful for your team?

It’s more the overarching theme that organizations need to build and foster a culture of compliance, ethics, and accountability. It’s not something you can switch on or off. It was a theme woven into many recommendations—an improved focus and intentionality toward creating a compliant, ethical, and accountable workplace.

As a result, people will naturally begin thinking, am I making the right choice? Am I setting the right example? Staff begin trusting each other more because we trust folks are holding themselves accountable, as well as others.

Seeing that within the recommendations was like an “aha” moment. It’s not necessarily a specific recommendation we can check off; it’s something we must continue to work on.

Does CMMB feel more equipped to navigate compliance and implement best practices effectively moving forward?

Absolutely. Our teams know what regulations are out there and which regulating agencies or forums we should look to for any changes to stay apprised of evolving situations. It gave us more confidence in our staff, the process, and the procedures and practices we had in place.

And knowing there were certain tasks or processes we wanted to document better, and now having documents behind these tasks is great. As I mentioned earlier, when someone wins the lottery and says, “That’s it, I’m retired,” we know we’re comfortable enough to pick up where they left off.

What would you say to other organizations considering a similar path with Humentum?

It was an amazing experience. Working with external consultants and ensuring that people understand what you’re trying to achieve on a specific timeline can be very difficult. The Humentum team understood these challenges, the ebb and flows of how we operate as an organization, and they worked with us to deliver on time. On the relationship side, it was fantastic. We are collaborating with folks who really understand the space we’re working in and our organization.

I recommend this to everyone because we're all trying to achieve our organizational missions. But without regular inspections of how we're operating to achieve those goals, we're never going to be as efficient as we hope to be. If there’s a way we can improve our processes, optimize how we work, and better serve the people we're trying to support—in my mind, it's worth its weight in gold.

Most organizations should go through this; even if you feel you are following best practices, you don’t know what you don’t know. Having an external network asking questions you may not be thinking about or phrasing them to unlock specific answers from staff is key. It’s looking into the details of the documents you have with a sharp, critical eye that you may be unable to provide within your company. It has raised the bar for us as an organization in ways that we didn’t expect.

About CMMB

CMMB (Catholic Medical Mission Board) is one of the world’s first and foremost faith-based global health charities, committed to healthier lives worldwide. Thanks to our supporters, and with a special focus on women and children, we work with global and local partners to ensure community-based access to quality care—by donating medicines, delivering health services, and deploying skilled volunteers—with lasting, lifesaving results.

For more information, please go to cmmb.org.

Humentum approaches NGOs as partners. Our experienced team of global consultants works side by side with the leadership team, always operating with full transparency and the goal of sharing knowledge.

From analyzing specific types of funding to assessing readiness and compliance or reviewing/developing compliance policies, we apply our expertise to help your team through the entire process. Find out more.