Gearing Compliance to the Tasks at Hand
Updated: Sep 11, 2020
I recently had the opportunity to travel to Chicago for my first SCCE Compliance and Ethics Institute (CEI), and attended a session “Keeping Compliance Simple,” which was led by Ricardo Pellafone, CEO, The Broadcat (www.thebroadcat.com) and John Partridge of Gibson Dunn. It was an engaging session, and it gave me an opportunity to reflect on their work in the context of some recent corporate engagements.
What first caught my attention was when Ricardo started the session by sharing that a compliance training program needs to address “the tasks at hand” to those on the front-lines of business. Does that sound obvious? Well, when we look at the complex challenges facing compliance and commercial teams, it might not be. Thus, I think we should heed to Ricardo and John’s reminder that an engaging compliance program is one that’s calibrated to help people execute with what they have been charted to do. Big and small.
In other words, as Ricardo well states, “give people something they can look at while they are doing their job.” I think that’s excellent thought leadership and advice. Do you expect your commercial teams to be subject matter experts on anti-bribery laws, facilitation payments, and export compliance, to name a few; or, would you rather give them something that they can read, reference, and which serves as a guide and guard-rail to their missions at hand? Ricardo’s right when he shares that “training around risk is problematic,” but compliance training which is oriented towards task completion and simplicity is a compliance program which is an active tool at the field level. And isn’t that we want?
A few weeks after the CEI, when presenting to a multinational, I had the opportunity to hear the CEO share some of his vision for growth, which inspired me to reflect on the ‘simplicity’ panel (FYI, when a CEO presents to a compliance/commercial team event, that’s a very loud spoken and unspoken message). When addressing corruption risk, he counseled the teams to “have a cleared-eyed view of the risks you face before you’re in the middle them, understand the resources available to make decisions, and then know how to engage.” If I had to think of one sentence which encapsulates what a simple yet resonating compliance program should look like at the front-lines of business, that would be it. While execution might not be so painless, having a compliance program which takes complex laws and regulations, and then translates them into how they apply to real-world scenarios, is a compliance program that comes to life.
Remember, when you hired those on the front-lines, you probably looked for individuals who could aggressively, ethically and compliantly execute on business growth and strategy. You might have even on-boarded some with risk-taking in their DNA. Thus, while it sounds easy to pronounce “grow the market, takes risks, but don’t break the law,” don’t those same teams deserve a compliance program which is simple, makes sense to their work, and which they can reference as a guide to success: One task at a time.
Ricardo was kind enough to detail the session for those who could not attend, of which the link can be found here. Image also courtesy and (c) The Broadcat