Bravado and humility

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.

Battle scars

You have an idea.

You know your idea can improve your E&C program and, as a bonus, your corporate culture.

But it’s never been done before. Your idea sounds strange to anyone who hears it for the first time. And you work for a conservative organization that sees risk over opportunity in every change. If you share your idea, you might get laughed out of the room.

What do you do?

It’s a very personal decision but it comes down to answering this question: what do you care most about?

If you care more about playing it safe and fitting in, you keep your idea to yourself. You can’t fail and you can’t be blamed for trying something that didn’t work.

If you care more about growing and learning and contributing to your organization’s improvement, then you make your pitch. You tell a story, one showing that you come from a good  place, with a good intent. You admit at the outset that it might not work. And that’s OK because you’ll either win or learn. Vulnerability connects people.

And battle scars are attractive*.

Embedded communications

Yesterday I was forced to host a call to bring colleagues up-to-date on a key project. Over the last weeks and months, I had not met the information needs of all stakeholders. As a group, we spent about 8 person-hours on this call. It would have taken me far less time to send them a brief email update each week.

We often neglect communications because we would rather do than talk about what has been or will be done. We have so little time to accomplish what’s on our plate, it seems logical to spend every minute doing the work.

What we fail to recognize is that the importance of communication is embedded within each project. If it’s important enough to be done, it’s important enough to be talked about, to be shared, for feedback to be sought, for accounts to be rendered.

As we determine how much we can have on our plates, and as we prioritize our work, we need to include a communication element to every project. Yes, this means that some projects won’t make the cut, at least not right away. But the projects we do work on will meet a greater degree of success. And the people we work with will perform better.

Who will change your corporate culture?

Humans tend to overestimate what they can accomplish in a day and underestimate what can be done in a year.

And for things that must take 5 or 10 years to accomplish, we often don’t even try. Changing a corporate culture is one of those things.

Of course, all we have to do is break down the process in small, manageable steps and move with the confidence that one day we will reach our goal.

If you haven’t read the book Primed to Perform yet, I highly recommend it. All you need to know about understanding, measuring and improving culture is within its pages.

Someone should be working to improve your corporate culture.

Might as well be you.

Complexity and good intent

The ethics and compliance professional will often face complex situations with no ideal solution.

Imagine writing a gift policy to prevent corrupt behavior. Or determining the discipline for an employee who should have known better. Or deciding whether to eliminate a long-standing employee program.

We can get paralyzed if we aim for perfection. We can waste precious time if we reach for almost-perfect. It is often best to simply proceed with all due speed towards a solution that matches our positive intent. We rarely go wrong when our intent is good.

How do we know that our intent is good? When we can articulate it openly to all the stakeholders.

Empathy

Compliance officers spend a lot of their time dealing with noncompliance.

If we let it, it’s easy to slip into a place where we assume that others engage in wrongdoing on purpose and with ill intent.

The cure is to remind ourselves of our own instances of noncompliance. When we were jet-lagged and tired and snapped at a colleague. When we made an inappropriate request because we didn’t understand the culture. When we acted on bad information. When we lied to protect a loved one.

It is true that good people do bad things. Including us. Whenever we see wrongdoing, we must use empathy to understand why it happened. Seeing how we behaved similarly in the past is a great hack.

To be clear, an employee’s wrongdoing, even when understood, will still need to be addressed through disciplinary action. But it can be done without bitterness or contempt. These two emotions do not serve us well.

Ground troops and air cover

Ethics and compliance professionals need one of two weapons in their arsenal, and preferably both.

First, the authority to decide on problems presented to them by employees. Second, the ability to escalate problems they cannot solve on their own.

Without these weapons, we are powerless to help. We (and others) soon realize that we talk a good game but can’t get anything done. Cynicism creeps in. When meaningful action is randomly taken, it is perceived as a double standard.

We all need ground troops and air cover. If you are missing either one today, devise a plan to acquire it.

CEO

I recently heard the story of a CEO who felt that his company would do much better if every employee behaved like a CEO.

So he created a huge banner that listed every employee’s name and asked each of them to create a new job title with the word CEO in it.

That would make each of us the Chief Executive Officer of Ethics & Compliance for our respective organizations.

If you had such a title, would it change how you fulfill your role?

The person and the process

When we investigate an allegation of wrongdoing by a fellow employee, we must remember that it’s not about the people. It’s about finding the facts and, if necessary, the flaws in our controls and culture that allowed the wrongdoing to occur.

At the same time, we must remember that it’s all about the people. They are colleagues to us and spouses, parents and friends to others. No matter how long they stay with the company, no matter how successful they have been or will be, they will remember being part of the investigation more than anything. It is a deeply personal moment, filled with uncertainty and vulnerability.

Respect the process, yes. But respect the person even more.