“The secret of getting ahead is getting started.” – Mark Twain 

“To succeed in life, you need two things: ignorance and confidence.” – Mark Twain 

Mark Twain would have been a great Chief Compliance Officer – he had an extraordinary ability to capture human behavior and motivation.  He would have known how to use the right phrase at the right time.

I can just imagine CCO Mark Twain meeting with the CEO.  Here is the conversation snippet: 

CCO Twain:  Well, I am concerned about our culture and cracks that I see that may portend problems down the road, especially as we seek to expand our business into emerging economies.

CEO:  I agree completely.  Our culture is critical.  Without our culture, our business plan, and perhaps our company, will fail.

CCO Twain:  As you know, we need to monitor, measure and enhance our culture through action and affirmative steps.

CEO:  Really?  How do we do that? Are you sure we need to do that?

CCO Twain: [Deafening Silence and perhaps a pithy quote].

My point here is simple but telling in today’s business world.  We all know what to say and how to say it, but we do not necessarily know what to do.  To boil it down, words are cheap and CEOs are in the business of “words,” and often ignore the need for action.

Corporate boards, CEOs and senior managers know what to say.  They are book smart and know what the right answer is.  But when you dig a little deeper that is when you encounter an absence of knowledge – you have exposed the shallow thinker.

Here is where the work for a CCO begins.  The challenge is how to educate CEOs, boards and senior managers without letting them know that is what you are doing.  I can always spot such a conversation when a professional speaking to a leader will begin a sentence with “As you know .  . .  .”

CCOs have shied away from facing the stark reality of their work – very few, if any, corporate boards, CEOs and senior managers understand the importance of an ethics and compliance program, and how to implement and monitor an ethics and compliance program.  This is a significant challenge.

It is distressing that corporate boards, CEOs and senior managers receive adequate training.  Many CCOs are reluctant to face this issue and recommend (or insist) on appearing before their corporate boards to ccondyct such training.

Even assuming that a CCO is able to secure adequate time before the corporate board and the CEO, a CCO has to engage in a delicate dance – how does the CCO explain to the board how the board needs to monitor and conduct meaningful oversight of the company’s compliance program?  A CCO has to get this message across without patronizing the board, which usually consists of significant business leaders with robust egos and personalities.

This is a challenge and a difficult one for every CCO.  Most that I observe and speak to about this issue have avoided the issue.  It is an important issue and, if handled correctly, can have a dramatic impact on the company’s ethics and compliance program.