Stop, Look, and Listen: Essential Skills for Driving Effective E&C Programs

By Vlad Kapustin, JD, CCEP, CCEP-I
From Compliance & Ethics Professional, a publication for SCCE members

“Stop, look, and listen.” It’s an idiom, or saying, that has withstood the test of time. You’re reading this, so you would likely agree you can’t go wrong with such a warning, given your own life’s experiences.

In the United States and elsewhere, you probably remember growing up and hearing those few simple key words from your parents, teachers, and any number of others interested in your well-being or safety. They wanted you to Be Prepared® (a motto we also recognize). The words “Stop, look, and listen” were said in an effort to have you exercise caution, especially at street corners and railroad crossings, by stopping, looking to the left and to the right (or right and to the left, depending on where in the world you resided), and listening for approaching vehicles or trains – in other words, impending risk.

Before the installation of gates and flashing lights in the United States, a road that crossed a railroad track had a signpost with an “X” on top. On the crossbars was written “STOP LOOK and LISTEN”. The phrase is said to have been credited to an anonymous train engineer who insightfully thought those few, very simple, and instructive words  would allow immigrants (who could only likely read English on a rudimentary level) to understand the three key words and pay attention to their warning. Now, automatic devices warn motorists and pedestrians to be mindful of approaching trains on the tracks and vehicles at crosswalks.

In the United Kingdom, its version was The Green Cross Code program created by the National Road Safety Committee over 40 years ago and continuing to this day as a multimedia campaign to raise awareness for pedestrian road safety throughout the UK. As you can likely tell from this messaging, this approach transcends borders.

Recently, while out with my family during one of our many sports tournament weekend trips, I was reminded of Stop, look, and listen. It happened while observing some careless pedestrians almost get hit when crossing the street (not by me, but by another motorist), and not long afterwards, actually seeing a motorist nearly crossing the tracks with an oncoming train approaching before, thankfully, stopping after either finally seeing the sign or maybe hearing a final warning of the train’s horn blaring. So the skills that we likely all learned from the phrase “Stop, look and listen” came to me as it relates to my world of Compliance & Ethics (C&E) and as a Certified Compliance and Ethics Professional.®

Listening certainly proved to be a vital skill, and it cannot be overestimated as a skill that is always in need of further developing, and not just for vehicles or trains, but in all that you do and should do when engaged with your organization’s C&E program.

This is why Stop, look, and listen are important.

Stop
“Stop” in order to best position yourself, so you’re not distracted and can take in what’s around you by not focusing on your own agenda or biased mental process. Set yourself free from influences other than your organization and what specifically impacts it, so you can hear and understand what the other person in front of you or others in the organization at all levels are saying. Decide with discipline to really hear what the person, department, or other stakeholder are actually saying or communicating.

Look
Actually “look” the other person in the eye when you are communicating, observing their emotions and any other non-verbal communication as well. Be very observant. Take in all the clues from the various forms of communication. This will not only provide sincere and genuine engagement, but offer a truly perceptive view of the organization through the perspective of all those persons whose actions may influence or impact the organization. Also “look” at all that may impact your organization from the outside, such as third parties, industry, peers, sector, geography, political influences, global enforcement, and guidance, etc.

Listen

By “stopping and looking,” you are now in a position to actually “listen” to what the organization is “telling” you about its risk. Also “listen” to what global enforcement is communicating.

So, the warning to “stop, look, and listen” will help you at a railroad crossing or crosswalk to be sure (certainly all of us can attest to this from their own personal experience), but also while you are engaged with your C&E program. It will help with our judgment too. In this context, the trains or vehicles are the misconduct or criminal acts that may cause harm to your organization, materializing from the red flags that will likely prove to impact your organizations. The dangers, accidents, or fatalities from vehicle and pedestrian accidents certainly were the basis for the “Stop, look and listen” warning, so this too can prove a lesson well-learned when assessing your organization through a risk-based, due diligence undertaking, and on an ongoing basis as you continue to monitor your organization’s activities or operations for impending risks.

Now, automatic devices warn motorists and pedestrians to be mindful of approaching trains or other traffic. Similar to these automatic devices that protect our well-being or lives, we now have the benefit of ever-evolving analytics and other risk-based tools that can serve and support your C&E program. As these automatic devices were designed to address specific risks to life and limb, so too, do we assess, design, tailor, implement, and improve programs using the foundation of what we all know as compliance and ethics professionals (Hint: U.S. Federal Sentencing Guidelines for Organizations, UK Joint Prosecution Guidance on Corporate Prosecutions, OECD Good Practice Guidance on Internal Controls, Ethics, and Compliance, and other significant frameworks and guidance in our balanced tool kits). Such are imperative to effective C&E programs and their important contributions to the well-being, productivity, and sustainability of our organizations and those that act on their behalf. So please, Stop, look, and listen.

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