For compliance officers, this is a stressful time.  How is that for another profound grasp of the obvious? 

Most compliance officers face a well-known assortment of risks — bribery, trade, False Claims Act, data privacy, cybersecurity and conflicts of interest.  Risks would move up or down depending on trends or specific industry operations. 

Further, with rapid technological change, new risks emerged such as artificial intelligence data security and privacy.  These are relatively new risks that have developed as a result of the Internet-based economy. 

Starting with this relatively stable risk environment, the Trump Administration has upended corporate risks and overall stability.  With rapid change and new priorities, the Trump Administration is modifying certain risks and elevating new risks. 

What should a compliance officer do?  How should ethics and compliance officers respond to this new world?

In the face of this change, my first recommendation is Do Nothing! and take a deep breath.  The cleansing from a deep breath can be remarkable.  Companies need to do the same.

With focus and determination, companies have to continue to publicize their commitment to their own values and principles.  Employees are looking for stability and a corporate employer can provide a steady beacon of stability.  Companies that overreact, bend over or sacrifice their values and mission will suffer immediate harm.  A company’s credibility is vital — when a company wavers, employees are unsettled and this can translate into loss of productivity and culture deterioration.

Instead of trying to adjust or modify a compliance program to respond to these new risks, companies should double down on their culture, reinforcing a clear message of commitment to its code of conduct, its values and integrity.  In a volatile environment, a company’s culture is the most important control to prevent misconduct.  Compliance officers have to redouble their efforts on culture — now is the time to assess, monitor and implement proactive strategies to protect and promote your corporate culture.

It is important for companies and compliance officers to view the current climate as creating a unique opportunity to advance the importance of a company’s culture, the need to promote civility, respect and adherence to corporate values and ethics. 

Leadership needs to step up and reinforce this messaging with calm and deliberate messaging on the need to maintain focus and stability. To that end, compliance officers need support and resources to enhance corporate culture initiatives. 

If a company responds in fear or with erratic messaging, employees are likely to sense a disruption to the steady confidence of corporate leaders.  Compliance officers have to craft messaging opportunities to advance this important goal.

Further, to reinforce this messaging, companies should schedule regular code of conduct training.  Most companies require code of conduct training for all employees each year.  This should continue and even increase to ensure full coverage in a year.

At the same time, companies have to monitor their culture by conducting surveys, tracking misconduct reports, and other valuable indicators.  As the geopolitical world changes, employees will naturally seek stability with their employer.  This is a terrific time to cement this important relationship between company and employee. 

A company’s most valuable intangible asset is its reputation and its culture.  Some have estimated that as much as 30 percent of a company’s stock price reflects the value of its culture and reputation.  From my perspective, I would bet that culture and reputation counts as much as 50 percent of a company’s stock price. With so much need for stability in this time of change, companies have to recognize the important role they provide in their communities and the need to reinforce this relationship.