Compliance Program Success: “Doing Better with Less”
Chief Compliance Officers always are asked to do more with less. It is a simple and overused phrase, usually promoted by corporate bean counters looking for ways to justify decisions that serve their own financial interests.
There has to be a better way to coin this phrase in the compliance context. CCOs are innovative and creative professionals. They like to embrace the concept of “leveraging” resources. That concept translates into a more accurate phrase – “doing better with less.”
The distinction is that CCOs know how to do “better” rather than “more” with fewer resources. How does this translate in the compliance arena? The answer is defined in the role of the CCO.
As I have written on many occasions, the CCO does not ensure nor guarantee compliance. To the contrary, the CCO leads by example and instills in the company’s business managers a process, or the tools, needed to ensure compliance in that manager’s operations.
This is the important transition between a CCO and company managers and employees. Compliance is not following a rule of law – it is more complicated than that. Compliance is embedding processes that business managers have to use to promote compliance and detect potential violations.
CCOs and business managers at every level in a company depend on this relationship and the successful dissemination of processes throughout a company. Please do not misunderstand my point – CCOs are not process integrators; in fact, they depend on a variety of professional talents: politicians, investigators, operational engineers, cheerleaders, parents, negotiators, therapists, and a myriad of other professions.
The one thing CCOs know how to do is make things work. If they do not, they are doomed to fail.
CCOs are problem solvers and they depend on the kindness of their internal business allies – CCOs need the business partners to do their job, and business partners need the CCO to promote ethics and compliance to ensure stability and productivity.
CCOs use their leveraging skills to enlist the support of internal business allies. It is critical to their success. When CCOs claim they suffer from a lack of resources, all that means is they need to go out and build alliances with internal business managers.
If they can convince the business managers to help, the CCOs will have access to some significant resources. CCOs have to embrace this strategy. It should work.
Companies are placing greater emphasis on compliance for obvious reasons. CCOs have more influence than they think. They just have to act on it and enlist the support of others in the company. When CCOs request help, senior management should support their requests and emphasize the need of internal business managers to help. One way for them to communicate this message is to designate business managers as process owners for ethics and compliance.