Ethikos Classic: Compliance: Beyond Reproach or Beyond Approach?

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Reprinted from the 2017 March/April Issue
Written by Scott Thompson

Which one are you (hint: they are not mutually exclusive choices)?

Synonyms for beyond reproach: blameless, exemplary, faultless, good, guiltless, impeccable, inculpable, innocent, irreprehensible, irreprovable, perfect, pure, reproachless, righteous, unblamable, unblemished, unimpeachable, virtuous (from Thesaurus.com).

The above adjectives are worthy character traits and goals to which compliance professionals, or arguably anyone, should aspire. However, if your fellow employees view you or the company’s Compliance function/department as unapproachable, similar to the image above, then it can have very negative ramifications for the company, even if you are beyond reproach. There could be numerous reasons Compliance is perceived as unapproachable: they are ineffective, they have limited power to assist, they have limited resources, they do not handle concerns in a timely manner, they do a poor job of communicating, they are heavy-handed when problems are raised, etc. The reasons can be varied and they can be complex. The reasons cannot be solved in a paragraph or two.

The point here is to think about being approachable in everything you do when designing and implementing compliance initiatives, and even in daily interactions with other employees. If your fellow employees cannot approach you (Bridge Out) or do not believe they can approach you (Road Closed), then everyone loses. Compliance initiatives have less impact. Problems go unsolved until it is too late.

Any compliance professional who has ever written a corrective action plan, made a self-disclosure to the government, or conducted a significant compliance investigation knows that fines, penalties, and other consequences probably could have been lessened in a particular circumstance if an employee had simply reached out with questions or to get guidance before acting or making a decision. Did your approachability impact their decision?

Being approachable is a key element in the continuous improvement feedback loop. Being approachable increases the effectiveness of your Compliance program. You want to hear from employees, and not just through the hotline. Employees know their voice will be heard if you are approachable and they will be more willing to raise concerns in a proactive manner. Aspire to be beyond reproach and to be approachable.

How do you make this a reality? Being beyond reproach is usually the easy piece for most compliance professionals. Integrity is a personal trait that either led them to the compliance profession or has helped them be successful in the profession. They pride themselves on doing the right thing and leading others to do the right thing. It is innate to them.  Being approachable takes effort and purposeful action directed at building relationships.  It is a skill that can be built and refined over time.

There is opportunity to demonstrate approachability in virtually every interaction you have, every hallway conversation, every presentation you make, every conference call, every meeting, every response to a concern that is raised, etc. After each of these interactions, ask yourself how you believe you came across to the other persons involved. Do you think you were perceived as a good listener, as a problem solver, as someone who could help make a difference, as someone who would make a diligent and good faith effort to find the best appropriate solution? Just as important, you have to follow through on any commitments you made in the interaction. Otherwise, you lose the credibility and goodwill you are trying to establish or have previously established with others.  In essence, you damage your approachability rather than build it.

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