For Compliance Officers, Patience is a Virtue
Compliance officers are, by definition, goal driven. They are high achievers and expect to succeed. So what, you may say – we all know that.
Compliance officers are not the most patient group of people. They want to see change, improvement and action. Patience is not in their blood, nor is it their middle name(s).
Unless a CCO is directed by the board or the CEO to improve a compliance program rapidly or the company is staring down the barrel of a government investigation, there are two important reasons for a CCO to move deliberately and with care.
First, new compliance policies and procedures cannot be rolled out, forced upon senior management and blindly embraced by employees. Instead, a CCO has to exercise patience and build the program, one brick at a time. Each brick has to be baked with care and evenly – meaning that there is top management support, buy in from key constituencies, and a commitment to action and follow up.
Before rolling out a new initiative, the CCO should ask several important questions:
• Do I have demonstrable support from the board and senior management for the initiative?
• Can I include that in the messaging and roll out?
• Do I have a compelling rationale for the new and innovative program? If so, is it adequately communicated?
• Have I adequately communicated the initiative to key internal stakeholders (e.g. HR, Legal, Finance, Business) to ensure their support and responsibilities, if any?
Taking time to roll out a new initiative is critical to ensure the support of key stakeholders. The ultimate success for the initiative will depend on whether employees embrace the requirements or responsibilities.
A second reason for patience is to build political capital. CCOs that develop inflated egos or beliefs in their own importance are doomed to fail. CCOs who operate with humility, determination and focus, and develop interpersonal alliances have a much better chance of succeeding. Of course, a CCO can only be as good as the board and the CEO support him or her in the mission.
It is a cruel twist of fate but when the leaders are not on board, a CCO suffers. Developing professional patience and understanding will go a long way towards success. CCOs need political capital for important junctions in their mission to establish an effective ethics and compliance program.
A CCO that works with patience and commitment has a much greater chance of support from leadership. This will translate into political capital. A CCO who acts too fast inevitably fails, on both fronts – organizational acceptance and political support.
I have seen too many CCOs fail when they roll out too many initiatives over too short a period of time. Building an effective ethics and compliance program takes a minimum of three years even under the best of circumstances.
A CCO who wants to demonstrate his or her capabilities cannot measure his or her performance by initiatives and change alone. Refocusing an organization takes time – I always liken it to turning a ship around (not a yacht, nor a sailboat, but a ship). CCOs need to take a deep breath and operate with confidence. Action does not mean competence. Wisdom reflects experience, confidence and patience.
Michael Volkov, CEO and owner of The Volkov Law Group, LLC, has over 30 years of experience in practicing law. A former federal prosecutor and veteran white collar defense attorney, he has expertise in areas of compliance, internal investigations and enforcement matters.
Mr. Volkov maintains a highly popular FCPA blog – Corruption, Crime & Compliance. He is a regular speaker at events around the globe, and is frequently cited in the media for his knowledge on criminal issues, enforcement matters, compliance & corporate governance.