Velocity Vehicle Group

Jeffrey Swett is the Chief Compliance Advisor and Legal Counsel for his company, bringing a wealth of experience in compliance and legal advisory roles. Since stepping into this position, he has established a comprehensive compliance program, overseeing compliance assessments, risk mitigation, and providing critical legal guidance across all business divisions. Previously, he served in significant leadership capacities, advising on complex regulatory matters and developing standardized processes to enhance operational efficiencies. Jeffrey’s background includes expertise in risk management, vendor due diligence, and acquisition compliance integration, making him a trusted resource for proactive legal and compliance strategies.

Through this article he highlights the importance of focusing on "Metrics that Matter" in compliance—measurable indicators that not only track activities but also demonstrate the true effectiveness and impact of compliance programs.

Most compliance professionals are probably familiar with metrics. After all, we want to be able to show that our compliance program is effective and drives the positive impact that we want, and the Department of Justice expects, in our organizations. But have we stopped to think whether we are measuring the right thing? Are we truly measuring “Metrics that Matter?”

Before I give examples of “metrics” versus “Metrics that Matter”, let me explain what I mean. A “metric” is simply something we measure as part of our compliance program. However, a Metric that Matters is one that goes beyond just measuring something—it helps us answer the question: So what? It helps tell us whether our compliance program is effective.

In addition to answering the “So what?” question, Metrics that Matter should have four characteristics. The metric should be easily understandable. In other words, the metric itself and the reason behind the metric should be obvious. The metric should be obtainable. If we cannot regularly and easily obtain the data, then it will not be a useful metric. The metric should be connected to a program goal. And the program goal should be derived from the Department of Justice guidelines. And finally, the metric should be repeatable over time. The metric should be used to show change over time—positive or negative—which can be used to identify risks and weaknesses in our compliance program.

  ​A Metric that Matters is one that goes beyond just measuring something—it helps us answer the question: So, what? It helps tell us whether our compliance program is effective  

Let me now talk about two specific examples of the difference between metrics and Metrics that Matter. I will start with one of the most common compliance metrics: training completion percentage. Important to measure? Yes. But does it answer the “So what?” question? Probably not. Consider having your employees rate the quality and effectiveness of the training. Consider asking your employees if the training made them aware of any current compliance violations and make sure to follow up on those concerns. Consider monitoring whether there is an increase in hotline calls or access to policies related to the training. These Metrics that Matter will better measure compliance program effectiveness.

Now consider another common metric: number of reports to the hotline. Important to measure? Yes. But does it answer the “So what?” question? Probably not. Consider measuring the percentage of the employee population contacting the hotline as compared to industry benchmarks in your industry. Consider measuring the percentage of employees who chose to remain anonymous. Consider measuring the number of calls that were substantiated versus unsubstantiated.

These are some basic Metrics that Matter. Make sure to consider your organization, its risks, and the maturity of your compliance program.

As you gather your data and present your metrics to your leadership teams, make sure you ask yourself: “So what?” Search for and challenge yourself to find Metrics that Matter. Make sure they are easily understandable, obtainable, connected to a goal, and repeatable. We will be more effective as compliance leaders. Our organizations will be better protected from risks. And we will have long-lasting, positive impacts on our organizations