How do you establish tone at the top when the CEO really does not care?

What if the Chief Compliance Officer cannot get the CEO’s attention?

CCOs face real challenges when the CCO does not have his or her star actor or actress to promote the company’s ethical culture. If you can imagine filming The Godfather without Marlon Brando, then you can imagine what a CCO must experience without the help or attention of the CEO.

The CCO should not give up. Of course, the CCO should try to convince the CEO to spend more time on ethics and compliance. The CCO should script a number of events, brief the CEO, and then have the CEO conduct numerous speeches, events, town halls and other activities designed to promote compliance.

Even if the CEO will not help, the CCO has to adopt alternative strategies. Nothing can substitute for a CEO’s performance. However, the CCO can enlist the support of board members, and other C-Suite executives and company officials to participate at ethics and compliance events. While the message will not be as strong, depending on the personal presence of the alternative company official, the message can still be communicated.

It is hard to overcome the absence of a CEO in a company compliance program. A CEO carries an important banner for the compliance program. Without a leader, it is difficult to sustain a message.

Internal pressure can influence a CEO to pay more attention to the issue. If the Chair of the company’s audit committee notices the absence of the CEO, the audit committee chair can raise the issue with the CEO. Furthermore, an internal compliance committee can include a recommendation that the CEO pay more attention to compliance issues as part of a set of proposed enhancements and evaluation of the company program.

Even if the audit committee or the internal compliance committee convinces a CEO to devote more time to compliance issues, there is no guarantee that the CEO will ever dedicate his or her heart to the effort. A lack of credibility could undermine the CEO’s effort. Managers and employees are able to discern when a CEO really means something or is going through the motions. The CEO has to learn that compliance is an important asset to attend to and promote.

Like the board of directors, CEOs enjoy business issues – strategic oversight and management of the company’s business. It is easy to ignore compliance as a lower priority on the list of financial issues.

Forward-thinking CEOs already recognize the importance of promoting compliance ass an important company asset. A culture of ethics and compliance adds to the financial bottom line and provides important insurance against systemic breakdowns in compliance. A CCO has a mission – to educate the CEO on the economic and strategic value of an effective ethics and compliance program.

As an advocate, the CCO has to be relentless in communicating ethics and compliance issues. Without being antagonistic, there are a variety of ways to ensure that ethics and compliance comes up often enough to remind, and eventually push, the CEO into the ethics and compliance space.