Renewing Corporate Vows to the Chief Compliance Officer
Our goals can only be reached through a vehicle of a plan, in which we must fervently believe, and upon which we must vigorously act. There is no other route to success — Pablo Picasso
The chief compliance officer is at an important professional juncture – 2018 is an important year for the profession. In this era of growth, and after corporate tax relief, companies have an opportunity to invest increased resources in their ethical culture and compliance program. This is an important point in the compliance officers’ journey up the corporate ladder.
By nature, I am an optimist. But I cannot espouse optimistic views in the face of growing concerns about corporate governance and leadership. We all want to believe that corporate boards and senior executives recognize the value of an effective ethical culture and compliance program. For many of us in the field, it is a no-brainer. Yet, moving corporate thinking and action is a difficult task. Our history has proven that over and over – most companies only embrace change when forced to by economic circumstances or government intervention.
The countervailing consideration to my pessimistic view, however, is the increased knowledge and research that has evolved over the last 20 years regarding the value of a robust ethics and compliance program. Some (or hopefully many) corporate leaders have embraced and promoted the value of an ethics and compliance program, citing the fact that an effective ethics and compliance program contributes to a company’s financial profitability and sustained growth. These leaders recognize that compliance has transformed itself into a bottom-line contributor instead of a separate cost center.
Companies need to re-examine their relationships with CCOs, and look to make changes – elevating the role and stature of CCOs, and most importantly, increase the resources allocated to the compliance function. All too often we see paper compliance programs with inadequate resources, struggling to accomplish important, and sometimes critical, tasks.
Corporate leaders need to take this opportunity to renew their vows and commitment to a robust ethics and compliance program. Corporate boards have to push this issue as a priority and dedicate time and resources to the compliance function so that compliance can contribute in economic good times and downturns. We appear to be entering a time of economic growth and this is the perfect time for corporations to begin that investment.
CCOs have to revitalize their own advocacy efforts. CCOs have enjoyed their rise in the corporate governance world, but now they have more to do. CCOs have to begin to advocate for entry and acceptance in the C-Suite, along with continued financial commitments from corporate leaders. CCOs have a long list of risks, projects, and tasks that need to be completed. But more importantly, CCOs need the respect (more than Rodney Dangerfield) in the corporate governance world.
Many corporate leaders have an unrealistic or narrow view of the importance and benefits of compliance programs. Too many corporate leaders continue to view compliance as a check-the-box exercise, a program with few benefits and necessary only to “keep the company out of trouble.”
CCOs have a mission – to educate and train their boards and senior executive teams. As part of this mission, they have to explicitly educate their boards and senior executives on the value of a robust ethics and compliance program, not as an insurance policy against violations of law, but as an economic driver, a contributor to the company’s overall success.
Forward-thinking directors and senior executives will understand and embrace the message and will ask the CCO what he/she needs to get the job done. CCOs have to be honest and let directors and senior executives know what the costs will be. Honesty is a must, and only with a candid back and forth, can a CCO’s relationship with the company survive. It all sounds familiar to any healthy human relationship, and that is why CCOs and corporations need to renew their vows of commitment to trust and integrity.