What Does Good Compliance Look Like?

Good ComplianceRichardBistrong-picture-small-768x1024By Richard Bistrong

At a corporate summit, the CEO of a Fortune 500 company started his talk by asking “what does good look like?” Good question.

“Rules often inspire legalism and minimalism,” he said. “But  they don’t govern behavior.”  He shared that compliance personnel face the challenge of impacting and inspiring people outside their formal perimeter, yet who are part of their team. In organizational chart terms, that’s about influencing the dotted lines of reporting, not just the solid lines.

During 2015, my first full year engaged with the compliance community, I realized that the compliance focus is about helping and supporting those in the field, often in remote and thinly supervised offices. It’s about finding and strengthening the weak links.

I used to think, through the prism of my experience, that compliance was focused on ‘catching people doing bad things.’ But the ‘catching people’ moment, I now realize, is when all else fails. As the former poster boy for a tight control regime, I now understand and  respect those distinct compliance goals, even if they are intertwined in the same program.

So I started asking myself, how can I help and support?  I started with prison, which was an awful experience. The family and health consequences were disastrous. So I started to share my experience as a ‘tipping point’ for those who confront similar ethical dilemmas that I faced, and which ended with my incarceration. I hope that a real-world crucible invites others to avoid that outcome by embracing compliance as a partner to success.

As my 2015 progressed, I started encouraging people to speak up when they feel that success and compliance are competing ideas and goals, as opposed to strategic counterparts.  I encouraged them to ‘call home’ first, but also to call compliance.  I also challenged compliance personnel to look from within to see if there were any  ‘unspoken’ organizational messages or silos that might be causing confusion in the field.

I spent the better part of my career avoiding and evading compliance. But I now appreciate that compliance leaders want those outside of their perimeter to be successful, and they want them home with their families.

I no longer call compliance personnel the “bonus prevention” people.  I call them friends and colleagues. In my next blog, I’ll get back to ‘what does good look like,’ and invite your thoughts.

*For those of you who are looking for the remaining content of this blog, being accustomed to longer pieces, welcome to my New Years Resolution.  From now on, I will be stripping down my blogs to  the “barest bone.” (See Zinsser, On Writing Well)

When in #FCPA doubt, call home and call #compliance. They want you successful and safely homeClick To Tweet

This post first appeared on Richard Bistrong: A Frontline Perspective on FCPA, Anti-Bribery and Compliance

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  1. Melanie Richard says

    Thank you for your insight. I had to do a double take when you said you were incarcerated. Yes, we want eveyone home with their families. I think we learned in our coursework for Health Information Management that its the processes where the problem lies, many times not the people. I am reading the book, “Drive” on motivarions. That’s why I found your blog this morning so moving. Daniel Pink in his book “Drive” talks about the Nobel Prize winner Daniel Kahneman, 2002 (on page 26), and his discovery that ” we weren’t always rational calculators of our economic self-interest and the parties often didn’t bargain for a wealth-maximizing result…we place too much emphasis on the economic and not enough on the human.” In essence, we are not hyperrational calculator-brained people. I will keep tuning in. Compliance is huge in Health Information.

  2. Christina says

    Thank you or the article, the shift from being a cop to being a support and strengthener is an important one and often neglected.
    Zinsser’s “On Writing Well” has been a big help to me for my writing (I realized I use too many words)

  3. says

    Thank you to Melanie and Christina for your kind replies and Melanie, I just ordered “Drive.” I was certainly an irrational calculator of risk (see Killingsworth’s posts on this subject), and I agree, there is not enough focus on the personal component, as the “what actually happens” in the field. As Killingsworth well states, none of this is an excuse for bad behavior, but what are the learning moments from a journey to the “dark side” of international business, as better understanding how those who work far away from home calculate risk and reward when making what could be fateful decisions. Christina, as this long reply indicates, as far as Mr. Zinsser is concerned, I have some room for improvement!

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