Compliance and Ethics Profession New Year’s Resolutions

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By Adam Turteltaub

As the New Year begins, I’m suggesting a few resolutions for everyone in the compliance and ethics profession.  Let me know what you think.  I’ve outlined three things we should stop doing and four things we should start doing, or at least do more of.

  1. Stop referring to “check the box” programs.  Every time someone says, “We have to move beyond check the box programs…” it makes people outside of compliance think that there are lots of check the box programs.  It also talks down to a lot of compliance pros.  I mean, how many people do you know in compliance who think they have a check the box program?
  2. Stop arguing whether ethics or compliance is better. It’s like arguing whether food or water is more important.  You need both.
  3. Stop expecting compliance programs to be perfect. Okay, none of us really do, but how many times have you heard a conversation among compliance people about, “when are these failures going to stop”?  As long as there are people around you can count on the fact that someone, somewhere will be doing the wrong thing.  And when they replace all or most of us with robots, sooner or later a robot is going to figure out how to cheat, too.  In the meantime, our job is to prevent as many failures as are preventable.
  4. Help each other more. You can begin by going on the social network sites for HCCA and SCCE to answer questions from other compliance people.
  5. Look for the next issue. It’s easy to get caught up in all the issues we know about, like privacy, and anti-corruption.  But, it’s also important to look to the horizon to see what may be coming next and start preparing for it now.
  6. Share your expertise outside of our conferences. We get hundreds more proposals for conferences each year than we could possibly accept.  But there are other ways to help others benefit from your experience.  Write an article for the SCCE magazine or the HCCA one, or for the blog.  Heck a blog post is only a page to a page and half long.  Or, let me know if you want to record a podcast.  Or, simply comment below.  You’ll see. It’s not hard, and it’s a start to contributing more.
  7. Take the time to understand people better. Compliance starts with the law but ends with people and what they do or do not do.  So, it’s time we spend more time understanding human behavior.  Read about why we cheat, or how we have ethical blindspots, or some other books that illuminate human behavior.

Those are my resolutions for the profession.  Let me know if you agree or disagree, and some other resolutions you think we all should make.

11 COMMENTS

  1. Some very good points, Adam on the “things to start”. I would re-order them, though:
    first – start to understand people better; then look for the unknown unknowns or the next issue; last share and interact more amongst the profession

    For the things to stop, I don’t fully agree. I think there are a lot of programs out there that are actually “ticking boxes” (not necessarily literally) but focussing on process & form (due diligence, “cover your behind” documentation, signoff, providing training because you have to, long & leaglistic SOPs policies & SOPs, brainless certifications…) over substance (human behavior, have people understood training and can apply it in their daily work… are we truly aware of conflicting interests …)

    About ethics & compliance – it’s not about what’s better. Of course they need each other. Ethics is the input. Compliance is an outcome, not a process. Complaince without ethics is blind. Legalistic compliance (we do all that’s legal; or “via negativa”, we don’t do what’s clearly illegal) is in essence unethical. “Just because you can doesn’t mean you should.” (Christian Hunt, Human Risk).

  2. Adam, I love your perspective. I know what I am trying to get people at my organization to understand , Compliance and Ethics go hand and hand. It seems that non compliance professionals are not on the same wavelength as Compliance and Ethics professionals.
    My favorite of your resolutions is #5. Look for the next issue. I am always mindful to watch for what is next, to me that makes things exciting to see what is next and to be ready to solve and resolve the next issue.We all have to be vigilant and find a creative way to be proactive for our organizations. Thanks for your insight.

  3. Thanks so much for this, Adam! I am guilty of focusing on “compliance” but 2020 is a new day in my organization. We are re-branding and it will be both “Ethics and Compliance” from here on out! I am supper excited. I am going to adopt a couple of your resolutions for sure!

  4. One of the most important areas I focus on is creating awareness on the important of ethics and compliance and generate a better understanding of how the ethics and compliance function adds superior value to the organisation in light of major new anti-corruption legislation impacting them, which come into force on 1 June 2020 in Malaysia. Thank you Adam for these resolutions!

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