By Jodi L. O’Neill, CCEP
Deputy Compliance Officer – Indiana Public Retirement System (INPRS)
I am a mom of two girls eight years apart. My oldest is a long-term planning, “Type-A” rule following mini-me. My youngest….well, let’s just say she’s not.
I could reason with my oldest at an early age. I could tell her to not do something with an explanation and for the most part, she was compliant. She was self-policing and motivated which enabled her to excel in school. We never worried about her missing curfew or the friends she hung with because she was just that good. We educated and trained her and she was compliant with minimal work.
The youngest, on the other hand, …oh my. That child could make me whip off my calm, cool and collected hat in a nanosecond!
One Saturday when she was almost three, she had lost cartoons, her favorite snacks and toy by 3 p.m. The timeout bench had been worn thin by the frequent visits of her tushy. I put a new bench on my shopping list.
She could predict the timing of her release from captivity and would ask, “Momma, can I get up now?” Before she was allowed up, she would have to state why she was there in the first place. On this day she surprised me by rattling off ALL the reasons she had been in time out. It ranged from poking our Doberman in the eye to throwing her sippy cup across the room out of anger that it was empty. I asked her, “You understand that when you do those things you will be punished, right?” To which she replied, “Yes.”
Hmmm…I just had to ask. “If you know it’s wrong and you know you are going to get punished, then WHY do you continue to do these things?” Her sweet little voice took on an air of sarcasm and she exclaimed, “BECAUSE I WANT TO!”
Explosive laughter threatened to blow my head off and I quickly ducked into the kitchen. Uncontrollable tears turned my mascara into black rivers on my cheeks. As I tried to pull myself together, her voice turned sweet again, “Momma? Can I get out now please?” I replied, “Nope. Sit there a few more minutes and think about your behavior.” I was the one who needed a few more minutes.
That sweet girl is now 12 years old. She receives frequent training and can regurgitate the answers to all the compliance and ethics quizzes. She knows how to use her resources and where to go for answers. She can even train others on compliance and ethics and help them understand that actions have consequences. But in some moments when she’s faced with a decision, all that training and instruction goes right out the window and she still does her own thing. More than once when asked why she did something, she has replied, “I don’t know! I just couldn’t help myself!” Ugh.
Compliance program outcomes can be a lot like my girls. On one hand, you can speak truth to your staff, train them well, and rest assured the message is received, heeded and acted upon with minimal work. Staff can pass all the quizzes and know where to find, and use, the resources. You aren’t worried about who they hang with because they are just that good.
On the other hand, you can do all the above only to have a few do things you know will land them and your organization on the business side of an investigation. Why? “I don’t know” or they “just couldn’t help themselves.”
Educate, train, and equip, but prepare for the worst. And if you get the equivalent of a rouge three-year-old testing your program, take a few minutes. Compose yourself. And put a new time-out bench on your shopping list. You just might need it before it’s over.