By Frank Ruelas
I’m going to cut right to the chase and ask the basic question (I think this is a great opportunity for a lesson learned from another industry) in the hopes people share opinions and ideas that genuinely reflect what compliance professionals deal with every day but is only spoken in hushed tones if spoken at all.
Brian Cullinan, the person who gave the wrong envelope to the presenters of the best picture award at the Oscars made a mistake. You be the judge and jury and decide based on whatever factors you want to consider on how you would deal with this from a possible sanctions perspective if you were given the task to do so.
Here’s my question:
Brian Cullinan is a partner at PwC. For the sake of discussion let’s consider that the mistake was made by a non-partner at PwC who was assigned “envelope handing duty” (maybe they won an employee contest to get this coveted duty). Do you think the same sanctions/disciplinary action/whatever you want to call it, if any, that would be applied to a non-partner would be applied to a partner for this mistake? What factors would you consider in assessing the appropriate level of discipline, if any, to those involved in this incident?
Certainly, it can be said that on some level, the strength of an organization’s compliance program is a function of the focus and attention that is given to tasks by the organization’s employees. According to reports about this envelope related incident posted online, Mr. Cullinan reportedly took a picture of the actress who just received the best actress award and then posted the picture on Twitter along with a few comments. So one could say that at or around the time of a very critical time of making sure that the right envelope naming the winner of the best picture was to be handed to the presenters, the “envelope handler” may have been distracted which may have contributed to the now infamous outcome.
So two takeaway points to consider:
First takeaway. If we expect people to comply with our compliance program we should make sure that the processes they are performing are such that the expectations are clear on what are their goals in performing their tasks. If there are possibilities that distractions could contribute to a less than desirable outcome, then everyone involved should discuss these and plan or build into the process steps to potentially prevent a less than satisfactory result. Sometimes these are identified in the process design phase, sometimes they aren’t. This is where the beauty of lessons learned can really come into play if we know of other organizations that have had similar challenges and we can benefit from learning through their pain.
The second takeaway is to remind ourselves that when we tackle the topic of sanctions, we need to understand that the person involved may be one piece of a larger puzzle that has to be looked at from a more comprehensive or macro level. There may need to be process tweaks that were not previously identified that should be considered when we see what happens in their absence. Sometimes we let the “who” is involved get in the way of asking and answering the questions of “why” did something happen.
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