Several years ago, I led a team of about 100 ethics & compliance officers (ECO) in one of my organization’s business units. I directly supported 6 Regional ECOs who in turn supported about 15 Local ECOs. Whenever we appointed a new Local ECO, the Regionals and I always covered conflicts of interests (COI) as part of our onboarding discussions.
Our message was simple: COIs are going to be your most common matters but that won’t make them any easier to solve at first. And our advice was equally simple: call your Regional ECO for help – she has resolved dozens of COIs. If she’s stumped, call me – I have resolved a few hundreds. And if I’m stumped, I know who to call for help.
Our goal was twofold: to offer support and to deploy some humility. By admitting up-front that we might not have the answer when they call for help, we gave these ECOs permission not to have all the answers for their employees on the spot. Being comfortable with saying “I don’t know but I’ll find out” is particularly important for E&C professionals. We go beyond simply asking “Can we do this?” and ask “Should we do this?” The first question might evoke bravado in some. The second question should trigger humility in all of us.