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CCOs Need To Adopt Their Own Code of Conduct

cco6As CCOs become a key player in the corporate governance world, ethics and compliance leaders are developing principles to be used by compliance pofessionals. It is a natural process that reflects the growing “professionalization” of the compliance profession.

It would be helpful for compliance officers to develop their own code of conduct, i.e. a set of general principles to help guide compliance professionals in their work.

Here are some suggestions:

Define and Adhere to Ethical Principals: As a profession, compliance officers need to define their own ethical principles and adhere to those principles. A compliance officer cannot operate like “Zelig” (Woody Allen’s movie) and adopt ethical principles that vary from organization to organization. In simplistic terms, this means that compliance officers have to define what they mean by “doing the right thing.”

Act with Honesty and Integrity: The compliance profession depends on honesty and integrity. A compliance officer has to provide others with honest and accurate information. There is no room for skewing data or information about business operations.   A compliance officer can set the tone for the compliance function by adherence to honesty and integrity.

Promote Ethics and Compliance as a Valuable Business Function: A compliance officer’s most effective tool is his or her communications skills. From the beginning, a compliance officer has to communicate and demonstrate the importance of ean effective ethics and compliance function, not just for staying out trouble or avoiding enforcement actions, but extending to the positive message – ethics and compliance makes a company more profitable. This is an important message to reinforce every day.cco

Promote Relationships and Learn to Listen to Others: A compliance officer must work with other key partners in a company by building positive relationships. Conflict will never result in anything positive. Instead, a compliance officer has to influence and persuade others to join in the ethics and compliance function, demonstrating along the way the importance to the organization’s long-term health.

An important part of this effort is to learn how to listen to others, to hear and to understand their concerns. Instead of focusing on how to reply to a person, it means to understand their concerns, empathize with their concerns and then address their concerns. A compliance officer has to operate with emotional intelligence.

As an active listener, a compliance officer can build a new perspective – one that reflects the ability to question his or her assumptions about any issue. A compliance officer has to accept the need to question his or her assumptions about an issue. From that approach, new ideas and innovative strategies often become apparent.

Work as a Problem Solver: A compliance officer has to be viewed as a problem solver, who never uses the word “no,” but instead says “how.”  This saying might be trite but it is important. As an active listener, a compliance officer has to understand the value of supporting the speaker, promoting the business, and doing so with proper regard for ethics and compliance. An important part of that process is for the compliance officer to develop positive working relationships with business managers and employees. The way to develop such relationships is to provide value to the business function by early identification and planning to avoid ethics and compliance issues. That planning process cco4depends on trust between the business function and the compliance officer.

Commit to Ethics and Compliance Programs that are Sustainable: The ultimate goal for a compliance officer is to build a sustainable ethics and compliance program that reflects the company’s values, holds people accountable for their actions (or inaction), and presents a consistent message internally and to external partners, constituents and consumers. A sustainable ethics and compliance program will contribute significantly to the ultimate success and growth of the company.

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