My blood went cold as I looked through my Twitter feed two weeks ago. Tom Fox posted that Volkswagen’s compliance officer had been arrested by the U.S. authorities for his involvement in the emissions scandal. “It’s finally happened,” I thought.
Over the next few days, Roy Snell and others pointed out that the man arrested was in operational compliance, which we see as different than “the compliance profession” as described within the SCCE. But to the prosecutor, the title “compliance” certainly didn’t protect the man from being charged. Being in the compliance profession does not shield us from prosecution (whatever our title may be) but instead, puts us in a sometimes-precarious position from which we must protect ourselves.
Most of us know that there have been several financial service compliance officers fined, sanctioned and threatened with jail time. Our jobs are inherently difficult, and anyone who has ever worked within a corporation knows that without the support of the business, the compliance team is lost. We can develop the most wonderful program and communication strategy, but if the business is actively hostile (especially at the top), no amount of skill can overcome that inertia.
I’ve performed keynotes all over the world, and inevitably after my speech someone asks me what to do because their company does not believe in compliance and is actively trying to thwart them. They always seem shocked when I answer, “You should probably quit.”
There is a big difference between a lack of genuine enthusiasm and active hostility. Many of us have to deal with inadequate budgets and lukewarm management. But active hostility should be a warning sign that you need to consider your own self-protection above your commitment to your employer.
It is easy for me to imagine a scenario where a compliance officer asks the business about allegations of impropriety. If the compliance officer were not able to ascertain the truth, and then passed on the business’ denials to the prosecutor, it isn’t hard to imagine that the denier might be included in charging documents.
Protect yourself. If you’re in a company that is actively hostile to compliance, brush off your resume, start browsing LinkedIn, and reach out to your network. This job isn’t worth your freedom.
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Kristy Grant-Hart the author of the book “How to be a Wildly Effective Compliance Officer.” She is CEO of Spark Compliance Consulting and is an adjunct professor at Widener University, teaching Global Compliance and Ethics. She can be found at www.ComplianceKristy.com, @KristyGrantHart and emailed at KristyGH@SparkCompliance.com.