Change and Project Management PDF

Summary

This document, Supplementary Guide 18, provides insights into change and project management procedures, essential for adapting to changing compliance obligations. It explores elements of change management, risk mitigation, and the role of compliance functions. This guide emphasizes the importance of effective strategies in a dynamic business environment.

Full Transcript

Generally Accepted Compliance Practice © (GACP) Framework Supplementary Guide 18: Change and Project Management 1 © 2024, All Rights Reserved Compliance Institute Southern Africa. Contents Introduction.............

Generally Accepted Compliance Practice © (GACP) Framework Supplementary Guide 18: Change and Project Management 1 © 2024, All Rights Reserved Compliance Institute Southern Africa. Contents Introduction...................................................................................................................................... 3 Definition of Change.......................................................................................................................... 4 Elements of Change Management Process......................................................................................... 5 Risks in Change Management............................................................................................................. 7 Management of Risk in Change Management...................................................................................... 8 Contributors for resistance to change............................................................................................... 10 Competencies and characteristics of a change agent........................................................................ 11 Developing a change management process for Compliance.............................................................. 14 Compliance Functions as Catalyst for Change.................................................................................. 17 Relationship between project management and change management............................................... 21 Phases of project management........................................................................................................ 22 2 © 2024, All Rights Reserved Compliance Institute Southern Africa. Introduction A change management process is essential as compliance with compliance obligations is not a static state but an ongoing process. Compliance obligations can change over time, and organisations must adapt their compliance practices to remain in compliance. A change management process ensures that any changes in compliance obligations are identified, assessed, and implemented in a timely and effective manner. Compliance policies and procedures need to be regularly reviewed and updated to reflect changes in compliance obligations, industry standards, and internal requirements. A change management process provides a structured approach to identify, analyse, and implement necessary updates to policies and procedures, ensuring that employees have the most current guidance for compliance. Changes within an organisation, such as mergers, acquisitions, restructuring, or new business ventures, can impact compliance requirements. A change management process helps assess the compliance implications of these organisational changes and ensures that compliance practices are appropriately adjusted to align with the new structure and operations. Implementing new technologies or upgrading existing systems can have implications for compliance. A change management process ensures that compliance considerations are integrated into the planning, implementation, and testing of technology changes. This helps mitigate any potential compliance risks associated with the introduction or modification of systems. Compliance changes often require employees to acquire new knowledge, skills, and behaviours. A change management process includes planning and implementing effective training programs to educate employees about the changes in compliance requirements, policies, and procedures. It also facilitates clear and consistent communication to ensure that employees understand the reasons for the changes and their role in maintaining compliance. Compliance is an evolving discipline, and organisations should strive for continuous improvement. A change management process facilitates the review and evaluation of compliance practices, enabling organizations to identify areas for improvement, address gaps or deficiencies, and enhance overall compliance effectiveness. 3 © 2024, All Rights Reserved Compliance Institute Southern Africa. Definition of Change Change can be defined as the process or act of making something different from what it was before. It involves transitioning from one state, condition, or situation to another. Change can occur in various aspects of life, including personal, professional, organizational, societal, or environmental contexts. Change management is an approach to transitioning individuals, teams, and change organisations to a desired future state. Change management is concerned with the sequence of activities, processes, and leadership issues that produce (organisational) improvements. It focuses on the values of cost, quality and schedule. 4 © 2024, All Rights Reserved Compliance Institute Southern Africa. Elements of Change Management Process Change Identification: Identify the need for change and define the desired outcomes. This involves recognising issues or opportunities that require change and articulating the goals and objectives of the change initiative. Change Impact Assessment: Assess the potential impact of the proposed change on various aspects of the organisation, including processes, systems, people, culture, and stakeholders. Identify potential risks, challenges, and benefits associated with the change. Stakeholder Analysis and Engagement: Identify and analyse the stakeholders who will be affected by the change. Assess their interests, concerns, and influence levels. Develop a plan for engaging and communicating with stakeholders throughout the change process to gain their support and address any resistance. Change Planning: Develop a comprehensive plan that outlines the strategies, activities, and resources required to implement the change. Define roles and responsibilities, timelines, milestones, and key performance indicators to track progress and ensure accountability. Communication Strategy: Develop a communication plan that outlines the key messages, target audience, communication channels, and frequency of communication. Ensure that the communication plan addresses the needs of different stakeholders and provides clear and consistent messaging about the change. Change Implementation: Execute the change plan by implementing the necessary actions, such as process changes, system upgrades, training programs, and organisational restructuring. Monitor the progress of implementation and address any issues or challenges that arise. Change Readiness and Adoption: Assess the readiness of individuals and teams to adopt the change. Provide training and support to help employees develop the required skills and competencies. Monitor the adoption of the change and provide ongoing support and reinforcement to ensure successful implementation. 5 © 2024, All Rights Reserved Compliance Institute Southern Africa. Change Evaluation: Evaluate the effectiveness and impact of the change initiative. Assess whether the desired outcomes have been achieved and identify any areas for improvement. Collect feedback from stakeholders and use it to inform future change initiatives. Change Documentation: Document the details of the change management process, including the rationale for the change, the steps taken, the outcomes achieved, and any lessons learned. This documentation serves as a valuable reference for future change initiatives and helps in maintaining organisational knowledge. Change Sustainment: Develop strategies to sustain the change over the long term. This includes embedding the change into the organisation's culture, systems, and processes, as well as establishing mechanisms for continuous improvement and monitoring. 6 © 2024, All Rights Reserved Compliance Institute Southern Africa. Risks in Change Management Consequences of when projects and initiatives are mismanaged from the "people side" of change management perspective include that results and outcomes are not achieved, and the likelihood of meeting objectives, finishing on time and finishing on budget is lowered. Three more perspectives add to the discussion about the impact of not managing change effectively in terms of costs and risks. COSTS RISKS Project level Project delays Resistance – active and passive Missed milestones Project put on hold Resources not Budget overruns made available Rework required on design Obstacles appear unexpectedly Loss of work by project team Project fails to deliver results Specific project costs Project is fully abandoned Specific project risks Organisation Productivity plunges (deep and Impact on customers al Level sustained) Impact on suppliers Loss of valued employees Morale declines Reduced quality of work Legacy of failed change Specific organisational costs Stress, confusion, fatigue Change saturation Specific organisational risks If the change Lost investment made in the Expenses not reduced is not project Efficiencies not gained implemented Lost opportunity to have invested Revenue not increased in other projects Market share not captured Specific costs if the change is not Waste not reduced fully implemented Regulations not met Specific risks if the change is not fully implemented 7 © 2024, All Rights Reserved Compliance Institute Southern Africa. Management of Risk in Change Management Actions to minimise risk associated with change It is evident that successful change management requires organisations to set employees up to succeed. Employees must be equipped with the tools, training and knowledge to work in new and different ways. Without these fundamentals, they will resist change and undermine the effort. In addition to aggressive risk mitigation, successful change strategies engage leadership at all levels. CEOs (or equivalent) and their direct reports must deliver a clear picture of their vision while openly addressing cultural concerns that could dampen efforts. They must share the business strategy and rationale for the change, which will inspire the organisation to embrace change. Responsibility, authority, power and influence in the context of change management It is evident that successful change management requires organisations to set employees up to succeed. Employees must be equipped with the tools, training and knowledge to work in new and different ways. Without these fundamentals, they will resist change and undermine the effort. Roles and responsibilities for change Understanding the roles and responsibilities in the change effort is essential. They will provide clarity on the expectations, scope and responsibility for each contributor/ stakeholder. Typically, there are four key roles: the Sponsor (Senior Leaders), Champion (Leader/ Initiator of change), Change Agent (Change Facilitator) and Stakeholder (Employees /Customers/ Regulators/ Suppliers etc). 1. The Sponsor is usually the Executive Manager of the Business Unit and: has the overall responsibility for the department initiating the change is the person who has authority over the change and over the individuals who will implement the change provides funding (finances and budget), approves issues and scope changes approves major deliverables and provides high-level direction (thus can be described as the powerful driving force behind the change) has a clear vision, identified goals and measurable outcomes for the change initiative. 8 © 2024, All Rights Reserved Compliance Institute Southern Africa. 2. The Champion is usually the manager in the Business Unit that: has the overall day-to-day authority usually foresees the need for change and therefore initiates the change provides the Sponsor with information about the issues, risks and challenges engages and involves the right people on the ground (change management team) brings the change vision to life encourages (and sometimes enforces) new and desired behaviours the champion therefore exerts influence over stakeholders in obtaining their commitment and participation in the change. 3. The Change Agent is the person that assists the department to implement the proposed change e.g. a consulting firm or internal project manager. Their role is to advise and guide the Champion and Sponsor throughout the change initiative and: focus on assisting, advising and coaching the Sponsor and Champion in the change effort may act in a number of roles – data gatherer, educator, advisor, facilitator or coach has no direct-line authority to or over the Sponsor or Stakeholders acts as a subject-matter-expert in the change management process. 4. Stakeholders are those employees/customers/suppliers, regulators, etc. who will be impacted by the change. As previously stated in more detail in this module, it is critical that they are involved in the process and understand how the change initiative will impact their current state. 9 © 2024, All Rights Reserved Compliance Institute Southern Africa. Contributors for resistance to change Typical contributors for resistance to change: Fear of change Not being consulted Poor communication Changes to routines Low trust Misunderstanding about the need for change Exhaustion / saturation Change in the status quo. Overcoming resistance to change 1. Empathy and support: find out how people are experiencing the change, which will assist in identifying people who are having trouble accepting the changes; the nature of their resistance, and ways to overcome it. 2. Communication: people resist change when they are uncertain about its consequences. Lack of adequate communication fuels rumours and gossip and adds to general anxiety regarding the change. When an effective communication process is in place it will reduce this speculation and remove unfounded fears and concerns. 3. Participation and involvement: an effective strategy for overcoming resistance to change is involving affected stakeholders as far as possible in planning and implementing the change. In this way a diversity of information and ideas can be shared which also contribute to ensuring changes are effective and appropriate. Participation also ensures that stakeholder interests and needs are accounted for, and commitment to the change is strengthened. 10 © 2024, All Rights Reserved Compliance Institute Southern Africa. Competencies and characteristics of a change agent A change agent is an individual, group, or entity that initiates or facilitates change within an organisation. Change agents play a crucial role in driving and guiding the change process, helping organizations or communities adapt to new circumstances, overcome resistance, and achieve desired outcomes. As per the above definition a change agent should: Know the business Compliance Officers may also play the role of a change agent at times. In addition to the following competencies of a change agent, the Compliance Officer must be knowledgeable about the environment and, just as importantly, about the business itself. If either of these were lacking, any change initiative would fail. Have a clear vision A change agent does not have to be the person in authority, but they must have a clear vision and be able to communicate that vision clearly with others. People get frustrated and non-committal if they feel that someone is constantly changing their mind regarding what they see as important and tend to change their vision often. Be patient, yet persistent Change does not happen overnight. A change agent needs to listen to people’s fears and concerns and gently but firmly convince them of the need for change. To have sustainable change that is meaningful to people, it must be something that they will have to embrace and see as important. Persistence means that the change agent will have to take opportunities to help people get a step closer often when they are ready, and not just giving up on them after the first try. Every step forward is a step closer to a goal; change agents just help to make sure that people are moving ahead. Have strong co-ordination skills In order to get all the ‘pieces of the puzzle’ together at the same time, a change agent must have strong planning and co-ordination skills. Where a significant change impacts many areas of the organisation, the change agent needs to bring these together in a way that ensures all deliverables from each area are ready by the same implementation/target date. Ability to communicate thoroughly, clearly and on all levels 11 © 2024, All Rights Reserved Compliance Institute Southern Africa. A change agent must be able to articulate the change initiative clearly to affected stakeholders in a way that will address their own concerns and advise them how the change will affect them in their own capacity. Depending on the level of staff, the change agent must have the ability to communicate at a business level, while at a more strategic level to senior management, for example. Have empathy and understanding This is the skill of understanding the feelings of another person. Empathy leads to improved communication and understanding between the change agent and organisation stakeholders. Be known to be trustworthy Change agents, need to earn the respect of leaders quickly so they will seriously consider the agent’s advice and factor it into their decisions. This is the foundation of a relationship of partnering that recognises the value each brings to the relationship. It begins with being trustworthy and demonstrating every day, in every way―from being on time (reliability) to being insightful (adding value). Have strong conflict management skills The ability to remain calm and objective and to help others work out their differences in constructive and positive ways. Rick Mauer has an insightful summary in his work on resistance: “level one—I don’t get it; level two—I don’t like it; level three—I don’t like you”. Change agents must develop the ability to understand when behaviours expressed as “I don’t like you” (anyone in the vicinity, but particularly change agents) are actually resistance to the change. Display resilience Resilience is the ability to absorb high levels of disruptive change while displaying minimal dysfunctional behaviour. Resilient people sidestep the dysfunctions of future shock because they are versatile and have a high capacity to rebound.” (“Human Resilience During Change”, Conner Partners White Paper). All individuals in the change benefit from developing resilience. Have strong relationships, built on trust All of the above means nothing if the change agent does not have solid relationships with the people that they serve. People will not want to grow if they do not trust the person that is pushing the change. Change agents should be approachable and reliable. People should never be afraid to approach a change agent based on their “authority” and usually they will go out of their way to connect with stakeholders. This doesn’t mean that they aren’t willing to have tough conversations though: that also builds trust. Trust is also built when someone will deal with things and not be afraid to do what is right, even if it is uncomfortable. Sometimes trust is built 12 © 2024, All Rights Reserved Compliance Institute Southern Africa. when you choose to do what is right for your community or organisation, as long as it is always done in a respectful way. 13 © 2024, All Rights Reserved Compliance Institute Southern Africa. Developing a change management process for Compliance Documented below is an example of a change management process for a compliance function Phase 1 Compliance Function Quality Assessment and Improvement Programme (QAIP) 1. In terms of Compliance function’s QAIP, the function is required to implement a new Risk Based Approach. Identify stakeholders 2. Identify the affected stakeholders (including stakeholders such as staff, divisions, departments are affected by the new Risk Based Approach) 3. Establish the stakeholders that are responsible for implementing the new Risk Based Approach. Actions to be taken: brainstorming the change and obtaining approval / commitment 4. A change management forum/team will assist in avoiding duplication of effort across areas, reduce cost and allow for synergies of deliverables. 5. Engage in a brainstorming meeting with change management team members regarding the impact on the business and a recommendation of the change plan is presented to the key stakeholder(s) for input. 6. Present the changes and change management plan to senior management i.e. how Risk Based Approach will impact them. 7. Ensure that top levels of management for the areas affected by the change are provided with sufficient information on the process changes to ensure their buy in and commitment to the changes. Size of the change: business project or organisational programme? 8. The requirements to implement the change such as resource requirements and the nature of change to be implemented, will determine whether project (e.g. when it has limited departmental or geographic impact) or programme (significant business impacted across several department and geographies) will be registered in the business: business will lead this decision. 9. Thus, register an official Compliance function project to implement the new Risk Based Approach. 14 © 2024, All Rights Reserved Compliance Institute Southern Africa. Communicate 10. Communicate to all stakeholders that a project has been registered to deal with the change (Risk Based Approach). Phase 2 1. Establish the project team responsible for implementing changes, made up of representative staff from within Compliance function. 2. The team will meet on a regular basis to discuss the progress of the implementation of the process changes. 3. The Change Manager will present to senior management the strategy for the change, such as the sequence of actions to be taken and how it needs to be done. Communicate 4. Communicate the change plan to all affected stakeholders after senior management has approved it. 5. Thereafter, communication of regular updates of the change must be made and feedback requested. Specific responsibilities during phase 2 6. A Compliance Function Change Manager, will need to do the following during the change lifecycle: Communicate any changes to the project team, to affected stakeholders on an ongoing basis. Review and advise on business requirements, training material, policy establishment / amendments, process changes, procedures and standards changes throughout the stages. Assist project governance structures on matters relating to change and remove obstacles as necessary. Participate actively in the project governance structures and provide ongoing feedback to Compliance Function Senior Management on the implementation progress. Participate in the project closure. 7. Furthermore, the change agent and change management team should continually ask the following questions during the change implementation lifecycle: Is anyone resisting the change requirements as defined in the business requirements and understand why? 15 © 2024, All Rights Reserved Compliance Institute Southern Africa. Are there actions that are not working? Are there organisational processes that are impeding efforts? Report any issues to the business owner/sponsor and Head of Compliance where necessary. Phase 3 Independent Quality Assessment After the new Risk Based Approach has been in place for a few months a Periodic Quality Assessment should be conducted i.e. review of a sample of Compliance Function engagements to determine if the Risk Based Approach have been effectively implemented. The outcome of the periodic assessment must be communicated regarding whether the Risk Based Approach has been effectively implemented, and report to appropriate levels of management as per the defined Governance Structures e.g. Oversight Committee/Audit Committee. 16 © 2024, All Rights Reserved Compliance Institute Southern Africa. Compliance Functions as Catalyst for Change The following example describes the Compliance Function’s role as an active catalyst to enable the organisation to embrace the change with consideration to all appropriate factors relating to effective change management: Phase 1 Compliance Advisory Engagement 1. Management requested that the Compliance Function should assist in the development of a new process for the Human Resource Department to assist in terms of the new processes required to comply with the new Labour Relations Act that has recently been enacted. 2. The new Labour Relations Act is researched, and a recommended new process developed and recommended to management. 3. In addition, e.g. management requested that Compliance Function must assist in the training of all relevant stakeholders regarding the new recommended process as well contribute to the implementation project. Identify stakeholders 4. Identify the affected stakeholders (including stakeholders such as staff, divisions, departments are affected by the new process) 5. Establish the stakeholders that are responsible for implementing the new process. Actions to be taken: brainstorming the change and obtaining approval / commitment 6. A change management forum/team will assist in avoiding duplication of effort across areas, reduce cost and allow for synergies of deliverables. 7. Engage in a brainstorming meeting with change management team members regarding the impact on the business and a recommendation of the change plan is presented to the key stakeholder(s) for input. Ensure the business risk appetite is taken into consideration when deciding on the course of action to meet the process change. 8. Present the changes and change management plan to senior management. 9. Ensure that top levels of management for the areas affected by the change are provided with sufficient information on the process changes to ensure their buy in and commitment to the changes. 17 © 2024, All Rights Reserved Compliance Institute Southern Africa. Size of the change: business project or organisational programme? 10. The operational / financial need versus the resource constraints needs to be observed and considered, thus informing a “do nothing” / “do” approach. 11. The requirements to implement the change such as resource requirements and the nature of change to be implemented, will determine whether project (e.g., when it has limited departmental or geographic impact) or programme (significant business impacted across several department and geographies) will be registered in the business: business will lead this decision. 12. Register as an official company project / programme if necessary. Communicate 13. Communicate to all stakeholders that a project has been registered to deal with the change. 14. Where the process changes relate to company-wide processes, it is preferable to start the communication process at an early stage to avoid unpleasant surprises and also to complement the feedback and brainstorming process. Phase 2 1. Establish the project / programme team responsible for implementing process changes, made up of representative staff from the affected areas of the business supported by relevant combined assurance staff. An accountable Business Owner will also need to be assigned to the change management team. 2. The team will meet on a regular basis to discuss the progress of the implementation of the process changes. 3. The Business Owner and Change Manager will present to senior management the strategy for the change, such as the sequence of actions to be taken and how it needs to be done. Communicate 4. Communicate the change plan to all affected stakeholders after senior management has approved it. 5. Thereafter, communication of regular updates of the change must be made and feedback requested. Specific responsibilities during phase 2 6. A Compliance Officer fulfilling an advisory and consultative role within a project / programme, will need to do the following during the change lifecycle: 18 © 2024, All Rights Reserved Compliance Institute Southern Africa. Communicate any changes to the project team, senior management and affected stakeholders on an ongoing basis. Review and advise on business requirements, training material, policy establishment / amendments, process changes, procedures and standards change throughout the stages. Assist project / programme governance structures on matters relating to change and remove obstacles as necessary. Participate actively in the project / programme governance structures and provide ongoing feedback to Compliance function Activity Senior Management on the implementation progress. Participate in the project / programme closure. 7. Furthermore, the change agent and change management team should continually ask the following questions during the change implementation lifecycle: Is anyone resisting the change requirements as defined in the business requirements and understand why? Are there actions that are not working? Are there organisational processes that are impeding efforts? Report any issues to the business owner/sponsor and Head of Compliance where necessary. Phase 3 Independent Assurance Engagement After the new policies, procedures, processes and standards have been in place for a few months or according to the defined Compliance Function Coverage Plan, conduct control adequacy and effectiveness testing. This will determine whether the new process is adequate (efficiently, economically addressing the risk) and effectively applied. This will to be conducted by a compliance officer who was not involved in the consulting engagement. The outcome of the assurance engagement must be communicated regarding whether the new process and relevant controls are adequately addressing the risk and is functioning effectively, and report to appropriate levels of management as per the defined Governance Structures. If it is found that the newly implemented policies, procedures, processes and standards do not sufficiently address the risk, the change processes will need to be revisited from 19 © 2024, All Rights Reserved Compliance Institute Southern Africa. start to finish, i.e. reviewing the controls, affected stakeholders, processes, forms, staff etc., in light of the assurance results. 20 © 2024, All Rights Reserved Compliance Institute Southern Africa. Relationship between project management and change management Change management incorporates the organisational tools, such as training, that can be used to assist individuals to understand what is required of them and, in the regulatory context, the consequences (personal or to the organisation) of non-compliance. Change management deals with the behavioural aspects of a project, while project management tends to focus on the technical aspects. Change management forms an integral part of the project, prepares the organisation for the project impact. Affected stakeholders should be included from the start of the project in order to eliminate any unwelcome surprises at a later stage. Successful projects integrate the two approaches, and make sure that equal attention is given to both the technical and the people side of the project. Where a project is initiated to address a regulatory impact, it is crucial that the compliance officer oversees the communication to and training needs of the relevant staff in the organisation. The project management team handles the technical and administrative side of the project, whereas the change management team handles the people side of the project. 21 © 2024, All Rights Reserved Compliance Institute Southern Africa. Phases of project management Origination or initiation phase During this initial phase, the need for the project is identified. The need might arise from new or amended legislation being implemented or even have come to light as a result of a monitoring exercise that highlighted unacceptably high regulatory risks in an existing process. Unless the need is well defined before the project proceeds, there will be much confusion as to the goals and deliverables of the project at planning stage with the resulting risk that the project does not happen at all. As soon as the compliance officer becomes aware of impending new or amendment legislation that will have even a minor impact on the organisation’s processes and procedures, s/he will need to assess the impact and follow the organisation’s policies and procedures regarding registering a project for implementation of the changes. The compliance officer must also identify all other related legislation to ensure that similar requirements are dealt with in one project at the same time to avoid re-work at a later stage. Essentially, the compliance officer should compile a compliance universe per project, e.g. for a data privacy and protection project, acts such as Protection of Personal Information (POPI), Consumer Protection Act and Electronic Communications Act may be included as they all contain elements of data privacy and protection. Planning phase During the planning phase, the project charter and business case are used to, inter alia, identify the agreed deliverables and timelines to meet the objectives and goals of the project. The compliance officer should evaluate these documents to ensure that the relevant compliance obligations and timelines will be satisfied. Execution phase During the execution phase of a project, the solutions proposed in the project plan are implemented. For example, system checks for flagging exceeding of regulatory limits in terms of an act are designed and implemented on the relevant system. A process for reporting these excesses is created. This is the phase where most of the physical, as opposed to thinking, work is done, and requires more effort than the other phases. Systems and process testing may be performed by the end users, i.e. the staff in the operations areas of the organisation, in order to 22 © 2024, All Rights Reserved Compliance Institute Southern Africa. confirm whether it will meet their requirements. The compliance officer must oversee this testing process to ensure that the end result fulfils compliance obligations. During this phase, the compliance officer should closely monitor: Time management: The compliance officer should check that the deliverables are on track to meet the relevant regulatory deadlines by when an act becomes effective Change management: Where regulatory projects are concerned, the compliance officer needs to closely monitor and assist management at the relevant levels, as well as the training department, to ensure a smooth transition into new processes and procedures. Project risk management: The compliance officer must be aware of all risks identified during all phases of the project and monitor their resolution through the progress of the execution phase to ensure that they are adequately managed through the outcomes of the project. If it becomes apparent that any identified risks will not be addressed in way that meets the organisation’s risk appetite, this needs to be brought to the attention of the risk committee through the relevant channels within the organisation. Issue management. Any issues that have been identified at initiation phase or that reveal themselves during the execution phase, need to be recorded in an issues log. Issues should be managed as they occur and the compliance officer must monitor these on a regular basis, especially during this phase, to assess whether they are being addressed satisfactorily through the implementation of solutions to meet the project’s requirements. Any issues that are not addressed satisfactorily must be closely observed and flagged. Issues such as the project being delayed may become a serious risk of non- compliance and thus a breach of legislation. Acceptance management. Acceptance may include user acceptance testing, before a new process goes live, as well as acceptance of the result by the compliance officer. Communications management: As part of the project life cycle, the team implements a communication process to make sure that all stakeholders are kept informed of the status of the project. Regarding regulatory aspects of a project, the compliance officer needs to monitor communications and updates regarding such regulatory aspects. The compliance officer should also consider if communication to the regulator is required. It is important to note that the compliance officer should not be responsible for the implementation or execution of a project, but to ensure that fulfil a monitoring/oversight and advisory role. 23 © 2024, All Rights Reserved Compliance Institute Southern Africa. Closing phase Before a project is officially closed, the project manager must ensure that all deliverables have been completed or finalised and accepted by the relevant stakeholders. A project closure report needs to be drawn up by the project manager, confirming that the objectives have been met, the deliverables have been handed over to the relevant stakeholders and that project closure can commence. Every Project Manager needs to complete a Project Closure Report to gain agreement from their Sponsor that the project is ready for closure. The compliance officer should ensure that the project is indeed ready for closure and that all compliance obligations have been satisfied. 24 © 2024, All Rights Reserved Compliance Institute Southern Africa.