By Ling-Ling Nie
Chief Compliance Officer & Assistant General Counsel
Panasonic Corporation of North America
When you woke up in the morning (or maybe much later in the afternoon like me) on January 1st, what were you thinking? As I flopped out of my bed, my first thought was to jump on my treadmill and erase all evidence of what I’d consumed over the past two weeks and achieve a supermodel physique. And then my second thought was to eat only things with leaves this year, while I redecorated my house like the cover of Better Homes & Gardens. I know most of you had similar thoughts, too. Over half the population makes some kind of New Year resolution. Yet, over 80% of those fail by the second week of February.
My (totally unqualified) opinion as to why this occurs is that we set ourselves up for failure when we strive for perfection. Nobody has a perfect body or a perfectly organized home. And certainly, obody has achieved the perfect work-life balance or perfect parenting model. We are essentially chasing unicorns and rainbows when we try to accomplish unrealistic ideals.
I’ll go out on a limb and say the same can be said about compliance programs. I’ve sat through enough webinars to recite the essential elements of a compliance program in my sleep, and I’ve researched and met with countless vendors to know the universe of tools and services available to compliance professionals like us. And if we each had unlimited resources, unbridled freedom, eternally cooperative employees, and a crystal ball to see beyond emerging trends, we could stand in front of our CEOs and guarantee a future with no compliance violations ever again!
But let’s get back to reality. The perfect compliance program does not exist. It never will. I was once given a Valentine’s Day card that said “You’re not perfect—but you’re perfect for me!” After I finished rolling my eyes, I accepted the statement as true. And it also applies here.
As compliance officers, we exist in an imperfect environment riddled with business risks, political uncertainty, and the unpredictable nature of human behavior. We deal with deficient budgets and outdated resources that make us choose which battles to fight and what risks to prioritize. But because of these challenges, we are forced to get to know our company like nobody else. We learn to leverage other departments to fill resource gaps. We learn what communication channels work and don’t work. And we learn our business, our leaders, and our market, so we can design controls and programs that will protect our company in the most effective way possible.
What results is a compliance program that is strong not because it is “perfect,” but because it is perfectly tailored to our company and our culture and our market. That kind of perfection is ok by me. As we usher in a new year, I’m making it my goal to ensure my compliance program remains customized to my company at all times. And frankly, I’m tired of chasing unicorns on the treadmill. Happy New Year to you all!