Do the right thing. It will gratify some people and astonish the rest. – Mark Twain We all know the obvious – a CEO’s commitment to ethics and compliance is critical to the success of a compliance program. A CEo who stands up and speaks about the company’s culture of compliance is more than a breath of fresh air – it can be the lifeblood...
This week I am devoting five postings to defining the “new” model of ethics and compliance – Compliance 2.0. If you read through compliance writings, blogs, articles, white papers, and other sources, you will see the term “Compliance 2.0” bandied about. It is a term that has yet to be defined but is taking on a life of its own – a reflection perhaps of...
Your CEO is either on board for compliance, or he/she is not. There is no half-way mark here, no way to deceive or soft-shoe your way through the compliance requirement. Yet it is common to see a CEO who is not committed and a Chief Compliance Officer who is in denial and points to half-hearted steps to justify their own self-deception. CCOs need to take...
Some things are easy to define by negative inferences. Corporate ethics or business ethics are not the same as legal ethics. Business ethics are not the same as our philosophy ethics – Aristotle and all of the classic philosophers were not operating in a corporate context. Some things require a positive definition. To bring about real change in the area of business ethics, a clear...
Before a Chief Compliance Officer accepts a new position with a company, a potential CCO should conduct his/her own “due diligence” of the prospective employer. A company without a corporate culture of ethics and compliance can pose serious challenges for CCOs seeking to implement an effective ethics and compliance program. In the absence of a real commitment from the board and the CEO, a CCO...
“It is Time” – Rafiki, The Lion King Corporate scandals continue to rack up – I am not just blowing smoke on this fact. Corporate boards are under greater scrutiny but the hardest place to bring reform is the corporate boardroom. Old institutions do not change quickly and there is an inherent resistance to change when it comes to a corporate boardroom. The old dynamic...
Compliance always boils down to people and interpersonal relationships. No man is an island, and no one can go it alone in compliance. One essential requirement for effective compliance is the ability to engage colleagues and your audience. Many senior executives are smart people –we all understand that. But too often senor executives embrace an interpersonal style of cheerleading. It allows them to appear to...
A Chief Compliance Officer has a number of important relationships to maintain in an organization. Aside from the support of senior level executives, the CCO has to build an effective working relationship with the board and the relevant board committee responsible for ethics and compliance. From an operational standpoint, a CCO has to use the board to advance an issue when frustrated by senior management....
Everyone likes to give advice on the importance of tone-at-the-top. Like many things in life, it is easy to talk about but much more difficult to implement. There are lots of ways to describe or analyze the same issue. In the end the result has to be reached. To boil it down, tone-at-the-top requires leadership. That is pretty obvious. But, what kind of leadership? This...
One person who does not have a conflict in evaluating a company’s reputational risks should manage a company’s reputation. This approach starts with one basic requirement – the board and the CEO have to agree that a company’s reputational risks should be managed and mitigated. As an initial step, the company has to assign responsibility for reputational risk to a senior executive responsible for risk...
