The New Test for CCOs

These are inspiring times for the compliance profession.  Looking back on the last ten years, it is amazing to observe the growth and influence of the compliance profession.  Many of the original advocates for the compliance profession must be impressed.  Corporate leaders are now embracing a new mantra – ethics and compliance.

Business ethics is a new focus and language all to itself. At the same time, CCOs are rising in stature within the corporate governance world.  Government prosecutors continue to focus on corporate compliance programs as a natural ally in the fight against corporate misconduct.

It is at this precise time, however, that CCOs face a new test and a new challenge.  I am not suggesting that CCOs should not enjoy their position today, but I am urging CCOs to use their new influence to embed ethics and compliance into the fabric of every company where they work.

CCOs are not naïve nor do they suffer from tunnel vision.  To the contrary, CCOs have an organizational view that is comparable to many senior executives.  CCOs are able to see across the organization how the company operates, how the company is performing and most importantly, how the CCOs culture is evolving.

CCOs have to become political actors.  CCOs cannot rely on their status by itself to gain influence and authority.  CCOs have to bring their own unique value to the table.  Not just an ethics and compliance perspective on every issue – but a business savvy, coupled with advancing the company’s culture and adherence to compliance.  This sounds like more than a mouthful, and perhaps my expectation is idealistic or unreasonable, but I have high expectations for the compliance profession, given the caliber of actors, the long struggle behind the profession, and the talented professionals who are attracted to the profession.

CCOs can gain even more stature within the organization by relying on one skill they uniquely possess – interpersonal skills.  CCOs are influencers, by definition, and they are often able to lead, persuade, and encourage corporate actors to embrace the ethics and compliance message.  Forward-thinking corporations quickly understand the importance of an ethical culture, and any CEO who has any shred of brains knows that a culture of ethics is an important economic driver for a company’s financial performance.

This is where compliance and business overlap, and this is precisely where CCOs need to develop their talents and influence.  When a CCO understands and commits to a company’s business, the CCO can bring ethics and compliance to the equation as another important investment for financial performance.

The next CCO test is very simple – to transform the message of compliance from “complying with the laws” to “promoting a sustained culture of ethics.”

CCOs have to understand their unique position – no one else will advocate for business ethics, no one else will push corporate leaders to embrace ethical culture as the protector of sustainable growth.  CCOs have to help redefine the message of corporate success by offering senior leadership a new mantra, a new contributor to a company’s success – an ethical culture.  But CCOs have to accomplish this task by using the language of business and by learning the ins and outs of the company’s business.  Once they are able to learn this language, CCOs have to bring the message of ethics and compliance to the specifics of business operations.  In doing so, CCOs have to explain precisely and with examples (and data) how an ethical culture improved employee morale, employee productivity, and ultimately contributed to the bottom line.  CCOs have to partner with marketing and sales staff to educate them on the value of a culture of ethics and using the company’s culture as a competitive edge in the marketplace.

CCOs should be proud of their accomplishments.  No one in the corporate governance world has experienced such a success story in the last ten years.  CCOs now stand at a new point, ready to take on new challenges.

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