This article initially appeared on The FCPA Blog, here and is reposted with the permission from the editor and publisher.
Former Goldman Sachs partner Tim Leissner testified at Roger Ng’s IMDB-related trial that he wanted to become a “hero” at the bank for bringing in billions in business, as reported in the South China Morning Post. Leissner’s “hero” remark struck a chord relating to my own professional journey.
In my career as a vice president of international sales for a global defense and law enforcement supply manufacturer — during years when domestic markets were going soft and other operating divisions were in the financial doldrums — I saw myself as a hero, delivering international sales growth while those other divisions were struggling.
I remember sales forecast meetings when all eyes were on me to make up for those deficits and to keep the top and bottom line safe. When I kept exceeding those forecasts, quarter over quarter, accolades poured in from both peers and supervisors, and I felt more and more empowered to do whatever it took to keep that success going. I didn’t want to give up my hero status.
While my decisions to be a hero with or without integrity were avoidable, and no one’s fault but my own, the internal and external forces to be the hero should not be underestimated.
Incentives, objectives — and even accolades — all have side effects. As compliance leaders, are you sitting with your business peers and challenging those objectives and rewards, even if well-intentioned, to make sure those side effects are aligned with your codes and values? Are you taking the DOJ Evaluation of Corporate Compliance Programs and bringing the section on “Has the company considered the implications of its incentives and rewards on compliance?” to life, through what might be difficult discussions with management on rewards?
Those conversations and questions aren’t likely to win any popularity contests, especially if you are challenging corporate heroes. But as I saw in my case, and as we’re now seeing from Leissner’s, bad behavior can hide behind good performance. It can lurk anywhere, especially in parts of the organization far from HQ which are often thinly supervised.
It’s in those remote corners, where leaders and others might be most reluctant to challenge the “success” or the integrity of corporate heroes. But I think it should be just the opposite. When we ask, “What’s behind good performance?” we build trust and integrity. We overcome what Amy Edmondson in The Fearless Organization describes as “dangerous silence” — the tendency to agree with the crowd rather than question what’s going on. Yet, as we continue to see in our enforcement news, success can block scrutiny anywhere in an enterprise, unless we ask tough questions, including: What lies beneath the success?
For me, after the music stopped, I wasn’t thinking at all about those years as a hero, with congratulatory emails, high-fives from colleagues, and being the star at those sales forecast meetings. When my criminal defense attorney called, letting me know I was the target of an FCPA investigation, my only thought was, “What was I thinking?”
For me, that’s when my journey from corruption to compliance started, and my illusion of being a hero rightfully disappeared forever.
P.S. To learn more about my journey From Corruption to Compliance click 👉👉🏽👉🏼 here.