By Alexandre C. Serpa
CCEP, CFE, Director of Business Compliance Officer for CVS Health Brazilian Operations
Take a look at a creek, what do you see? Some stones are certainly there, somewhat static and simple, but also strong and long lasting. There is definitely water, ever flowing water that meanders through, over and under the stones. The water is, opposite to the stones, alive, fluid, in constant change, and able to adapt to the position of those stones. Sometimes the water flow is also enough to move the stones. The movement may be small, almost too small to be perceived, but it could also be that the water flows so rapidly that the stones are completely dislodged from their initial positions.
One can’t stop the water from flowing, unless one builds a dam, but a dam will change the creek to something other than a creek. However, one can move the stones and change their relative positions or rearrange them by size and those changes will affect the course of the creek, without removing its creek-nature.
The water flow will be affected by the seasons, by the volume of rainfall, by other animals that may also reshape the creek by changing the position of the stones and the change in the water flow will always interact with the stones. Water and stones will always be playing a fluid version of a tug-of-war and that is the nature of a creek, an everlasting battle of fluid and static that gives the creek its beauty.
Our compliance programs are like creeks. At least, we should want them to be exactly like a creek for if you want your compliance program to be effective it will need some stone like components while maintaining a fluid nature.
Think of the seven pillars of a compliance program as the stones in the creek. The pillars are, technically and methodologically speaking, very simple, very static, very standard elements. One can very easily learn how to implement and manage those pillars it only takes some training. But when the water is added to the equation is that our compliance programs come to life. The day-to-day reality of our companies is like the creek’s flowing water. The reality of a company – therefore that of a compliance program – is fluid. No day is like the other. The reality of a company will push the pillars of your compliance program, be it for adaptation or for circumvention, and your compliance program has to respond to all the variations of the water flow and the pressures it exerts onto the stones. At the same time, you do not want to add so many, big stones that you end up creating a damn that will stop your company’s operations and normal routine.
See, build, manage and enjoy your compliance program as if it were a creek, and its effectiveness will come naturally as a creek’s beauty does.
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