How do you define what you do?
I look for quantifiable risk areas in Gallup’s business lines and try to educate, monitor, and control variables that might expose Gallup to the ill effects of violating laws and regulations that present those risks.—William (Bill) Kruse, Vice President- Law & Counsel/Regulatory Compliance Officer, Gallup Connect with Bill on LinkedIn
Retired but still engaged in the Ethics and Compliance Profession on a part time basis supporting the SCCE Academies and Institutes and serving as a mentor and coach to any person in the E&C Profession or looking to enter the Profession.—Al Gagne, CCEP, Former Director Ethics & Compliance, Textron Systems Corporation (retired) Connect with Al on LinkedIn
Helping companies to stay out of trouble, and B., doing so in a way that they can show (i.e., prove) that they really were a good guy trying to do the right thing.—Theodore L. Banks, Partner, Scharf Banks Marmor LLC www.scharfbanks.com
I help corporations and outside counsel simplify their translation/eDiscovery workflow for global FCPA, IP, Ethics & Compliance investigations/litigation. From a proactive perspective, I assist global corporations to localize their Codes of Business Conduct, Anti-Bribery and Anti-Corruption programs as well as any policies and procedures. We match domestic project management with a global network of native speaking in-country linguists to ensure that the mission critical compliance tools, resources and messaging are properly translated and disseminated to a global workforce. It’s part logistics, part production management, and it all works by leveraging Merrill Brink Ethics & Compliance language solutions expertise for the benefit of our corporate and law firm compliance colleagues.—Jay Rosen, Vice President, Language Solutions, Merrill Brink International http://www.merrillbrink.com/legal-translations.htm, Connect with Jay on LinkedIn
What do you wish you had known when you started?
That building an effective compliance program is a process and not a list of activities to check off – and the process is 3-5 years so it’s important to have a long view as well as an annual plan—Sally March, JD, CCEP, CCEP-I, Director, Drummond March & Co. Connect with Sally on LinkedIn
I started in the world of broadcast communications, and what I wish I had known then at the age of 19 was that I should have attended a course in how to navigate corporate politics. However, that very first corporation experience has led me to what I am doing today, so wouldn’t have missed it in retrospect – we should learn from all experiences we have.—Jane Mitchell, FRSA–Director, JL&M; Chair, eCP Connect with Jane on LinkedIn, Follow Jane on Twitter
A strong linkage to the CEO is the first, second and last requirement for creating and implementing effective compliance programs. The compliance officer must be keenly sensitive to the challenges the CEO is facing. Often, the CEO’s attention will by necessity shift to other programs and needs beyond compliance. So the compliance officer may find that the budgets and attention given to compliance projects will shift (up or down) from time to time. This can create lots of frustration for the compliance officer. Accordingly, he or she must create a compliance roadmap that can be adjusted to accommodate these variations in both budget and executive attention. However, with both patience and persistence, the compliance officer can champion a program that develops and improves consistently over time.—David Birk, JD, Black Belt Compliance, LLC www.blackbelt-compliance.com
There are very few “easy” questions. Compliance and ethics are rarely black and white. People who think of themselves as good often do bad things for a variety of reasons.—Theodore L. Banks, Partner, Scharf Banks Marmor LLC www.scharfbanks.com
The importance of a well alligned strategy. Compliance can’t operate on its own and it is not something that just happen. It is not that kind of service that is so much in demand that people will just approach you. It is therefore important to know what your organisation’s expectation is of Compliance and to also know where the company sees compliance in the future.—Paul Zietsman, Trade Compliance Lead Specialist, Sadara Chemical Company Connect with Paul on LinkedIn
When I started in the profession there was no SCCE, so I sort of evolved into and E&C Professional. I would have really benefitted from the many practical hands-on course offerings now available to folks now. In particular, how to conduct an Effective Internal Investigation. The basic skills associated with conducting investigations are learned skills that need constant honing over the years. Life is a bit easier for todays E&C Professional as most of the skills and knowledge needed to succeed are easily accessible.—Al Gagne, CCEP, Former Director Ethics & Compliance, Textron Systems Corporation (retired) Connect with Al on LinkedIn
I wish I would have known that I couldn’t do it all in one day. Companies are like big ships, and big ships take time to make course corrections. Getting buy-in takes time. Getting plans communicated takes time, and changing perceptions takes time.—William (Bill) Kruse, Vice President- Law & Counsel/Regulatory Compliance Officer, Gallup Connect with Bill on LinkedIn
What is the most important thing for a new compliance officer to know/learn?
How to find the right tool to solve or manage a problem. As with any task, having the right tool can mean the difference between effectiveness and epic failure. Sometimes, technology is your friend. First, you need to understand the challenges you have and then, you need to be smart about sniffing out the right tool to manage it.—Amy Hutchens, JD, CCEP, President & Founder, CLEAResources, LLC www.clearesources.com
E&C Professional should know the Key Elements for Implementing an Effective E&C Program and being able to successfully communicate them to others in their respective organizations.—Al Gagne, CCEP, Former Director Ethics & Compliance, Textron Systems Corporation (retired) Connect with Al on LinkedIn
Don’t underestimate the time needed to transition. I tell lawyers it takes a year to make the transition to thinking like a compliance officer.—Sally March, JD, CCEP, CCEP-I, Director, Drummond March & Co. Connect with Sally on LinkedIn
Listening is usually more important than talking.—Theodore L. Banks, Partner, Scharf Banks Marmor LLC www.scharfbanks.com
You need to know the risks your company is facing and in order to know that, you need to know the business.—Paul Zietsman, Trade Compliance Lead Specialist, Sadara Chemical Company Connect with Paul on LinkedIn
What skills are essential to be successful as a compliance officer?
The role requires a combination of social and technical skills. The ability to influence those in the boardroom and the executive suite, while also resonating with the rest of the enterprise, is based on social skills such as advocacy, believability and empathy. At the same time, the ability to design and introduce effective programs requires technical skills such as project management and organizational change management.—David Birk, JD, Black Belt Compliance, LLC www.blackbelt-compliance.com
To be successful as an E&C Professional one must develop and utilize excellent communication skills. Being a good listener tops the list along with being accessible to all stakeholders by being quickly responsive to any and all E&C questions and concerns along with all reports of misconduct.—Al Gagne, CCEP, Former Director Ethics & Compliance, Textron Systems Corporation (retired) Connect with Al on LinkedIn
Having people trust you is the most important skill. If they don’t trust you to know your job, know that company, and know how to help them achieve the company’s goals without just being a roadblock, you won’t get the cooperation necessary to ensure compliance. –—William (Bill) Kruse, Vice President- Law & Counsel/Regulatory Compliance Officer, Gallup Connect with Bill on LinkedIn
Good communication and influencing skills, and a very good sense of humor—Sally March, JD, CCEP, CCEP-I, Director, Drummond March & Co. Connect with Sally on LinkedIn
To be an effective compliance officer you need to have mastered every area that was presented to you when you got that liberal arts degree in college. This includes: understanding the details of the Federal Sentencing Guidelines (political science), understanding how companies work (business), understanding the way that incentives drive behavior (economics), understanding why people do things (psychology), knowing how organizations function (sociology), understanding how to educate adults (education), understanding how to communicate with adults (English Comp.), understanding how to use technology to manage the program and understand technology-based risks (computer science); understanding how to work with others (politics/psychology/sociology), and understanding basic legal principles (law)—Theodore Banks, Partner, Scharf Banks Marmor LLC www.scharfbanks.com
What is your biggest day-to-day challenge?
I am not a compliance officer, but the biggest day to day challenge I face as a consultant is keeping clients/organisations safe in the knowledge that doing the right thing will be good for business, but it is likely to require some courageous conversations on the way, and some effective dot connecting. In silo-driven organisations, this is of course, often tricky!—Jane Mitchell, FRSA–Director, JL&M; Chair, eCP Connect with Jane on LinkedIn, Follow Jane on Twitter
My biggest challenge as an E&C Professional was keeping the message fresh by spending more of my time on the proactive elements of the E&C Program rather than the reactive elements, for example trying to focus more on targeted education and positive reinforcement of the company values which I believe would eventually result in having to spend less—Al Gagne, CCEP, Former Director Ethics & Compliance, Textron Systems Corporation (retired) Connect with Al on LinkedIn
Interested in learning more? Each expert that contributed to this week’s posts is also speaking at our Annual Compliance & Ethics Institute, Sept. 14-17 in Chicago, Illinois. For more information, visit www.complianceethicsinstitute.org