I concluded Part II of “What Good Compliance Looks Like” with “compliance and tone at the top are more than stated values, it’s about operational and unspoken values. It’s about a seat at the table of business strategy.”
But what of corporate integrity, where does that intersect business strategy, operations and values?
How about this: “integrity has become such a buzz word that I think it’s lost its meaning.” But wait, the I in that sentence wasn’t me, it was Hui Chen, DOJ Compliance Expert, in an interview with Laura Jacobus on the ECI Connects Blog (here). Ms. Chen added that when integrity can be defined and articulated as to “how that plays out in their (employee) day-to-day work,” then it becomes much more than an overused buzzword.
But how? It goes back to the compliance challenge of shaping and impacting employees who are outside their organizational perimeter. As Ms. Chen states, it’s about addressing those parts of the organization where compliance does not have ownership all “functions and processes.” But how can a compliance officer, often seated at the home office, with possible budgetary restraints, and who might or might not be familiar with the cultural, political and ethical challenges that different regions present, break through the barriers and achieve Ms. Chen’s “cross-functional commitment and collaboration.”
In sales, we used to speak of “force multipliers.” Those were individual’s or agencies who served as powerful references for other potential customers. In the defense industry, having your product evaluated and purchased by a special weapons or special forces team would serve as a such a strong market indicator. Thus, by focusing on a smaller group of recognized end-users, a sales team might secure a favorable market reference that would then get amplified to the wider marketplace. It’s a more deliberate form of ‘word of mouth,’
So, where are the compliance force multipliers? Are there employees who can serve as compliance ambassadors, driving ethics and compliance to the front-lines of international business? Do they exist?
The answer came to me this week in preparing for a global corporate event. In this multinational, the Chief Compliance Officer delivers a powerful message to international sales and business development managers: “You are not a passive recipient of our compliance programs. You are compliance.” He recognizes that compliance can’t be everywhere, and that to populate new compliance manuals to cover every permutation of human behavior and risk, would be a lot less effective than to create an army of compliance envoys as part of being an international sales executive.
And to create that cadre, you don’t need an outside consultant, professional or practitioner. What you need is a vision, and to trust. Michael McAlevey, Chief Legal Officer and Business Development Leader for GE Aviation, in an article Ethical Leadership: How Does It, and Should It, Shape Corporate Compliance? (Ethisphere, Q4/2015), states, “where trust and individual freedom co-exist, there is less reliance on process and bureaucracy.” While those on the front-lines need to embrace compliance programs and compliance personnel as a partner to success, compliance needs to empower and trust those in the field as the front-line messengers of ethics and compliance to their peers and reports. You can’t convey that in a manual, but when that two way trust is achieved, it is the ultimate compliance force multiplier.
Autonomy and rules, as Mr. McAlevey states, “live in tension.” He adds, “process and regulation cannot and should not reach to every corner of corporate life.” Challenging your front-line executives to deliver integrity and compliance as a path to success, is part of what Mr. McAlevey speaks to when he references Lord Moulton’s “obedience to the unenforceable.” It’s about “doing the right thing where there is no one to make you do it but yourself.” Empower your leaders to that standard and watch it cascade throughout the organization.
That’s compliance as much more than a PowerPoint or on-line training. That’s empowerment, trust and creating a sales team that is compliance, and which brings Ms. Chen’s “commitment of the whole company to compliance” to life.
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This post first appeared on Richard Bistrong: A Frontline Perspective on FCPA, Anti-Bribery and Compliance.