What Does Good Compliance Look Like?
Updated: Sep 8, 2020
At a corporate summit, the CEO of a Fortune 500 company started his talk by asking “what does good look like?” Good question.
“Rules often inspire legalism and minimalism,” he said. “But they don’t govern behavior.” He shared that compliance personnel face the challenge of impacting and inspiring people outside their formal perimeter, yet who are part of their team. In organizational chart terms, that’s about influencing the dotted lines of reporting, not just the solid lines.
During 2015, my first full year engaged with the compliance community, I realized that the compliance focus is about helping and supporting those in the field, often in remote and thinly supervised offices. It’s about finding and strengthening the weak links.
I used to think, through the prism of my experience, that compliance was focused on ‘catching people doing bad things.’ But the ‘catching people’ moment, I now realize, is when all else fails. As the former poster boy for a tight control regime, I now understand and respect those distinct compliance goals, even if they are intertwined in the same program.
So I started asking myself, how can I help and support? I started with prison, which was an awful experience. The family and health consequences were disastrous. So I started to share my experience as a ‘tipping point’ for those who confront similar ethical dilemmas that I faced, and which ended with my incarceration. I hope that a real-world crucible invites others to avoid that outcome by embracing compliance as a partner to success.
As my 2015 progressed, I started encouraging people to speak up when they feel that success and compliance are competing ideas and goals, as opposed to strategic counterparts. I encouraged them to ‘call home’ first, but also to call compliance. I also challenged compliance personnel to look from within to see if there were any ‘unspoken’ organizational messages or silos that might be causing confusion in the field.
When in #FCPA doubt, call home and call #compliance. They want you successful and safely home
I spent the better part of my career avoiding and evading compliance. But I now appreciate that compliance leaders want those outside of their perimeter to be successful, and they want them home with their families.
I no longer call compliance personnel the “bonus prevention” people. I call them friends and colleagues. In my next blog, I’ll get back to ‘what does good look like,’ and invite your thoughts.