Corporate Clergy: Role of Compliance Officer Involves Communicating Meaning, Importance of Ethics

(This article was contributed to Corporate Compliance Insights by Mr. Paul Liebman, Chief Compliance Counsel at Dell Inc. in Round Rock, TX. Mr. Liebman can be contacted via email at Paul_Liebman@Dell.com.)

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Compliance Officer Role: Corporate Clergy

Those of us who have been in ethics and compliance roles for a long time know that we wear many hats. Sometimes, we serve in a “Army Corps of Engineers”-type role, building out the structure (the roads and bridges as it were) of the programs. Other times, we act in a “Police Department”-type role, investigating the facts and allegations of ethical or legal breaches.

However, perhaps the most important role we serve, at times, is that of “Corporate Clergy”. In this role, we advise business leaders, and leaders in other administrative functions (e.g., Human Resources, Internal Audit, Legal and Finance — collectively our corporate partners) on what it means to be ethical and legal.

We advise on what compliance really means.

I had a CEO in a previous life deem ethics and compliance as the religion of the organization; he dubbed me Corporate Clergy and told me to go spread the message. It’s not an easy role, even in good times, as most people in their personal lives would not want to have their minister or rabbi hanging over their shoulder preaching all the time about the consequences of their choices. It is even tougher in the professional or corporate context, especially in the challenging economic climate we find ourselves in right now; but I believe that Corporate Clergy is a key role we play, and there has never been a more important time to play that role well.

Role of Compliance Officer Involves Communicating Meaning, Importance of Business Ethics

In this economic downturn, it is important for us to help our leaders lead. We can do so by creating messaging that they can use to remind their direct reports of the following. For example:

“The financial climate may be tough now, but in times like these we need to remember to not only outperform the competition, but to also outbehave them. When the economy recovers, we want to be poised to capitalize on the opportunities.

“So do not let the pressures of the current downturn drive you to do things for short-term profit that you know, or should know, are wrong. They are more likely to have significant, long-term negative implications for you and the company.

“Do not take illegal or unethical short cuts and remind your direct reports that profits never trump legal and ethical behavior. Show them that you will lead by example by encouraging them to come forward with questions or concerns, and to report suspicious behavior. Let them know that they can also talk to someone in HR, Legal, or Ethics and Compliance, and that they can be anonymous if they like by calling the company Hotline.

“Remind them that nothing is hidden in today’s environment; everything is discovered and made public eventually.”

These messages are particularly effective when they are directed at the specific activities of the business.

For example, the above type of messaging can be tailored at Sales employees by telling them not to try to reach sales goals through dishonesty, bribery or fraud, or by skirting any required legal and accounting review processes, or by engaging in behavior that would embarrass them or their company if it became public.

Finance employees might get a message that implores them not to try to show growth or profitability by using overly aggressive accounting interpretations, by ignoring bad financial news in required reporting, or by failing to question others when things don’t look right.

For Marketing employees, the message might focus on trying to reach goals through deceptive advertisements, or by making promises that cannot be kept.

Manufacturing, Research and Development, and other groups can be reached this way as well.

You hear a lot about tone at the top these days but tone at the middle and tone at the edges is just as important. As an ethics and compliance professional, you need to find the right tools to spread the right messages to all employees, wherever they may be located, and whatever they may be doing.

Make sure that middle-level management has the messages to spread and that third party partners on the edges of your supply chain or distribution channels get them too. Have them use your corporate websites, e-mails, blogs, and vlogs to get the message out most effectively. Think creatively about how your employees actually communicate with each other, and take advantage of more personal methods like texting or social networking sites, where appropriate.

This economic downturn will pass. The question is whether our corporate behavior during the downturn will pass the test.

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Paul Liebman is Chief Compliance Counsel at Dell Inc. in Round Rock, Texas. The views expressed above are his own. You can contact Mr. Liebman at Paul_Liebman@Dell.com.

Tags: business ethics, Dell, economic downturn, paul liebman, role of compliance officer