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A Presentation to Compliance Professionals: Rationalization Not Justification


On Thursday June 12, 2014, I was asked by Mike Kenealy (FCPA IntegrityCOO) & Craig Chadwick (Global Secure Summit) to address a group of Compliance Professionals from the financial sector in NYC. In my presentation, I shared my experiences from the field of international sales, including encountering foreign bribery, cooperation, and finally, my perspective on current compliance challenges. A group of the attendees remained after the presentation, where we discussed the challenges of  aligning strategy, compensation & compliance, so that they all speak to the same message of anti-bribery compliance.  That discussion was in the context of how and why compliance efforts fail at the field, especially in the environment of a public company, where profit and sales growth over the short and long term are critical for return on investment and shareholder value. 

I was very much impressed as to the questions asked by the attendees who remained. Clearly, they understood the challenges that their international front line business groups face, and they were very much focused on “what can we do to help.”  Furthermore, as the conversation progressed, they acknowledged how incentives and sales forecasts could actually contradict or distort the messages of compliance and ethics, especially from the perspective of those operating in high risk international  environments.  We talked about the importance of listening to those in the field and how, as I shared, “the more disturbing those conversations might be, the better they are progressing.”  They clearly grasped how front line international business people are the most important element in executing an anti-bribery and corruption program, and how it is the responsibility of compliance professionals to give them the tools of success. 

Rationalization is not justification

I could see from the feedback that I have received since the presentation, that there was indeed value to the practitioners in hearing a voice from the field of international sales, as I spent a great deal of time explaining my own perfect storm of “rationalizing bribery.” There was more than one question asked, as to “what were you thinking,” and I believe that the components of my “rationalization” model helped to break that down in a way which was understandable, relevant and engaging. There was also a great deal of discourse on my discussion of corrupt third parties and how it is often difficult to detect their “circle of lies” when it comes to investigations and vetting. 

But, as I shared at the start of my presentation, almost as a preamble, rationalization is not justification. I knew what I was doing was wrong,  and accepted responsibility  for my conduct, including the loss of liberty.  Now, the question remains, does that experience bring value to other individuals and organizations in their own  compliance challenges? Based on the dialog after the presentation, it certainly did on June 12th, and if it continues to  helps others, I remain open to future opportunities.

Thank you again to FCPA Integrity and GSS for the invitation.

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