So, for those of you who missed last year’s “The Grinch Who Stole Compliance,” never fear: We have an endless supply of compliance-related holiday mirth. After all, who doesn’t like a bit of eggnog and the traditional singing of “Have Yourself a Very Compliant Christmas” at the company holiday party? So along those lines, here are a few fun facts about “The Twelve Days of Christmas” that you probably didn’t know:

• “The Twelve Days of Christmas” first appeared in print in 1780 but as a poem, not a song. The composer Frederic Austin set the poem to music in the early twentieth century and memorialized the current words, including by making some alterations, such as changing “four colly birds” to “four calling birds.”
• Historians believe the poem originated as a “forfeit game” for children, which required that each child repeat and add a verse. If the child made a mistake, he or she had to “forfeit” a candy, a small token, or a kiss. To make it even more challenging, the last verse was to be recited all in one breath.
• Although most people believe the tune is referring to 12 days leading up to Christmas, the song actually starts counting on December 25 and ends on Twelfth Day (January 6), also known as the Feast of the Epiphany. The 12 days mark the time in the bible between the birth of Jesus Christ and the arrival of the Three Wise Men, the Magi, who visit bearing gifts.
• Most of the animals mentioned in the song were not gifts — they were intended to be eaten. Even the reference to “Five Gold Rings” isn’t a reference to medieval bling but rather a ring-necked pheasant.
• If you add up every single gift in the song, each time mentioned, you end up with 364 gifts in all … one for each day of the year, excluding Christmas. This is most likely a coincidence.
• Most importantly, historians have unearthed the earliest version of the song, which shows that the song was an early form of compliance training! In other words, it was called …

The Twelve Days of Compliance

On the first day of Compliance, Legal gave to me:
A handbook of company policies.

On the second day of Compliance, Legal gave to me:
Two ethics courses,
And a handbook of company policies.

On the third day of Compliance, Legal gave to me:
Three risk assessments,
Two ethics courses,
And a handbook of company policies.

On the fourth day of Compliance, Legal gave to me:
Four forms for filing,
Three risk assessments,
Two ethics courses,
And a handbook of company policies.

On the fifth day of Compliance, Legal gave to me:
Five audit plans!
Four forms for filing,
Three risk assessments,
Two ethics courses,
And a handbook of company policies.

On the sixth day of Compliance, Legal gave to me:
Six policy updates,
Five audit plans!
Four forms for filing,
Three risk assessments,
Two ethics courses,
And a handbook of company policies.

On the seventh day of Compliance, Legal gave to me:
Seven reports due Friday,
Six policies changing,
Five audit plans!
Four forms for filing,
Three risk assessments,
Two ethics courses,
And a handbook of company policies.

On the eighth day of Compliance, Legal gave to me:
Eight trainings pending,
Seven reports due Friday,
Six policies changing,
Five audit plans!
Four forms for filing,
Three risk assessments,
Two ethics courses,
And a handbook of company policies.

On the ninth day of Compliance, Legal gave to me:
Nine reports a-writing,
Eight trainings pending,
Seven reports due Friday,
Six policies changing,
Five audit plans!
Four forms for filing,
Three risk assessments,
Two ethics courses,
And a handbook of company policies.

On the tenth day of Compliance, Legal gave to me:
Ten new directives,
Nine reports a-writing,
Eight trainings pending,
Seven reports due Friday,
Six policies changing,
Five audit plans!
Four forms for filing,
Three risk assessments,
Two ethics courses,
And a handbook of company policies.

On the eleventh day of Compliance, Legal gave to me:
Eleven risks to manage,
Ten new directives,
Nine reports a-writing,
Eight trainings pending,
Seven reports due Friday,
Six policies changing,
Five audit plans!
Four forms for filing,
Three risk assessments,
Two ethics courses,
And a handbook of company policies.

On the twelfth day of Compliance, Legal gave to me:
Twelve headaches pounding,
Eleven risks to manage,
Ten new directives,
Nine reports a-writing,
Eight trainings pending,
Seven reports due Friday,
Six policies changing,
Five audit plans!
Four forms for filing,
Three risk assessments,
Two ethics courses,
And a handbook of company policies!

And so the moral of the song is: Don’t issue a bunch of new compliance initiatives all at once; develop a long-term rollout plan so personnel aren’t overwhelmed with new compliance dictates. Well, either that or don’t drink too much eggnog, or you will have 12 headaches pounding — we’re not certain which. Either way, we wish that everyone has very happy — and compliant — holidays, and we look forward to starting up our biweekly emails in the new year.