Often, The Best Compliance Presentations Are After The Compliance Presentation
Updated: Aug 17, 2021
Over the past three weeks, I have had the pleasure of presenting to and engaging with, compliance and commercial leaders in some wonderful venues including Prague, Malta, and Dubai, as well as Miami, Houston, and Dallas, back at home.
It was an incredible three weeks, where I had the opportunity to exchange perspectives with compliance, commercial and business leaders from across functions, markets and regions. It was clear to me as I looked out at the audiences that ethics, compliance, and integrity issues were being taken seriously by everyone, and not just those teams tasked with developing, implementing, and rolling out a program. The questions that I had the opportunity to address were both challenging and thoughtful, many revolving around very tough, real-world scenarios that confront both commercial teams and the compliance leaders tasked with keeping them both successful and safe. Much of my responses, which I will address in future blog posts, revolved around the challenges of how to make difficult issues discussable, and how to spark and create an environment where people feel comfortable talking about the risks they face before they are in the middle of them.
It’s what Mary Gentile, author of Giving Voice to Values, refers to as “pre-emptive rationalization,” where we want to encourage people to share what are often inevitable challenges in advance, as to allow an entire team to unpack those dilemmas and to reduce the ‘power of the moment,’ which can tip people in the wrong direction. And we shouldn’t underestimate the ‘power of the moment,’ where employees might feel ‘on-the-spot’ to make a decision and take the least path of resistance, which might be a shortcut that’s not in anyone’s interest. But by teasing out those moments in advance, by recognizing that people’s values might get challenged when trying to achieve their objectives in tough commercial environments, we can spark a discussion as to the world of ‘alternatives,’ which can reduce the sway of even well-intentioned assumptions that can put everyone in harm’s way. As Mary shares, “if we can name the argument in advance, we can reduce its power because it’s no longer assumed.”
Indeed, as Dr. Alexander Stein, (Founder, Dolus Advisors), recently shared with me, “problems often arise not just because of an absence of, or departure from, positions of shared values and principles or an abandonment of ethics or rejection of integrity, but because in a clinch moment somebody may not actually know how to do what needs to be done, AND do the right thing. Because in that environment and in that moment those two things might seem, or even be, utterly opposed. And in that moment, in that environment, corporate policies are of no help. Operationalizing ethics means helping people make real-time ethical decisions on-the-fly and on-their-own, which isn’t at all the same as helping people know and understand the parameters of ethical decision-making that’s expected of them by corporate decree.” To which I would add, Alexander’s moment is often a nano-second, and it can come at the worst possible moment of time, in jet-lagged, sleep-deprived environments, where people are struggling with their objectives, and a decision is at hand.
It’s at that point-in-time that the relationships and discussions which compliance leaders have built with their workforce will come into play. When those connections have been formed and nurtured in a safe-zone, where everyone is willing to show a little vulnerability, humility, and humanity as to the often subtle and real-world forces that can impact decision making, then when that difficult moment arises, the power of the moment will have been replaced with the world of alternatives. And it’s right there where globally disbursed teams will know who they can talk to, and they will be proud, as well as inspired, to work in an organization which welcomes transforming the difficult into the discussable.
Finally, a suggestion, relating to the title of this blog post: If you are a compliance leader or corporate event planner, during your next training session or event, where you might only have a limited amount of time to allocate compliance on a busy agenda, plan that presentation before a break or meal, as to give compliance leaders some time to ‘hang around’ the podium and take continued questions, and/or to network on the coffee line! As I experienced over the past three weeks, those are the conversations worth waiting for, where people might feel less reserved in asking a question or setting out a possible workforce issue, in a more personal environment.
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