Do what you can

Few things are as disheartening to an ethics & compliance officer than to feel powerless against a senior management team who doesn’t walk the talk.

In an ideal world, the ECO could simply say to senior management “Wait. You say that X is important but you don’t put any resources into it. Either we admit that this is not important or we allocate the necessary resources.”

But we don’t live in an ideal world. So what are other actions an ECO can take? Here are some suggestions:

• Use a real case. Present the findings of a recent investigation to senior management. In a non-accusatory way, show how the organization could avoid another violation if more were to be done. Don’t blame them for their failure to act more aggressively in the past. Instead, present this as an opportunity to become better.
• Find an ally in the c-suite. If they don’t listen to you, they might listen to one of their own. Can you have a candid conversation with one of them, one you know could take the baton?
• Create demand. Discuss the issue of concern with as many middle managers as you can. Don’t point the finger at senior management. Instead, genuinely try to identify ways by which middle management can solve the issue on their own. Because a solution is unlikely, these sessions will agitate the crowd and senior management could be forced into action.
• Use the helpline. Force senior management to respond to your concern by using your anonymous helpline. You’ll want to make sure they can’t trace it back to you. You may not get a real answer, or you might get empty promises, but at least you will create a discussion in the c-suite and put them on notice that not everyone is fooled by talk that doesn’t match the walk.

You don’t have to be successful in any of these attempts. You simply need to keep trying.