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Compliance Leadership Tips from the Surgeon General

Tom Fox recounts some lessons learned from a recent New York Times profile of Surgeon General Nadja Y. West. Her guidance is widely applicable to leaders across industries and specialties, but some of her insights are real nuggets of wisdom for the compliance practitioner in particular.

For me, September 11 is the most solemn day in the history of our country that I have lived through. Others of my parents’ generation point to December 7 with the same reverence I feel as the day America was attacked. Just as December 7, 1941 forever changed the world, 9/11 changed the world, with its effects still being played out on the world’s stage today. Each year I take time to remember all those who lost their lives, loved ones and all those who suffered from the horrendous events of that attack upon America.

Leadership encompasses many ideas, concepts and techniques. I explore some of these on my podcast 12 O’clock High, a podcast on business leadership, and I regularly visit these topics on this blog. One thing about leadership is that it works on many levels so that many of the techniques that would make you a more effective Chief Compliance Officer (CCO) in your corporate compliance function can also be used to make your compliance program stronger within your company.

I was reminded about this intersection when I read a recent New York Times Corner Office column by Adam Bryant where he profiled the U.S. Army’s 44th Surgeon General, Lt. Gen. Nadja Y. West, in a piece entitled “People Can Tell If You Care About Them.” It probably would not surprise you to find out that Lt. Gen. West was an Army brat growing up, and that upbringing imbued her with a deep duty to serve our country.

Somewhat surprisingly for a serving Lt. General, West noted a key leadership lesson was empathy. She stated, “One characteristic that stands out in all the leaders I’ve seen is empathy. You don’t have to be like everyone else, but you can try to connect with other people. People can tell if you care about them or not.” The reason empathy is so important is that “you have to show soldiers and the people who work for you that you may not know where they’re from or their background, but you’re responsible for them and you try to figure out the best way to connect with them. If you treat every human being with dignity and respect, you can’t go wrong.”

Being a doctor, in addition to her role as an officer, West also has learned “how to encourage people to do things that they might not want to do.” West explained, “You don’t want to scare your patients or chastise them. You can talk to them all day long and explain to them what’s happening, but if you don’t really understand what’s going on in their lives or why they can’t do what you’re asking them to do, it can be frustrating.”

West noted that one of her first leadership lessons was persuasion. Not being able to simply order a patient to do something, she had to get her patients to move in the direction she wanted them to move. To do so, she found she had to use some different approaches than simply ordering them to do so. However, this approach made her less decisive as a military officer, so she had to learn to find the right balance in each approach and for each situation she faced.

West learned a very interesting lesson from one of her key mentors, General Lloyd Austin III. General Austin asked her “What job do you want to do?” Being a good soldier, West replied “Well, sir, I’ll do any job that the Army gives me.” However, Austin explained to her there was more to the answer than her direct response, responding, “I’m sure you will, but what would you like to do? Because if you don’t ask for the jobs that you might be interested in doing, the answer will always be no.”

West also learned a valuable lesson from General Colin Powell: it is always a good thing if people come to see you. As a leader, always take time to listen to their problems or concerns. Powell had ingrained in her that “the day soldiers stop coming to you with their problems means one of two things. One is that you can’t help them because you’re not capable of helping them, or the other is that you don’t care.”

I found this lesson particularly applicable to a corporate compliance program. Some view no issues, problems or even comments to the compliance function as a sign that there are no problems. However, it may well be that you cannot or will not help them; that, or the compliance function will not provide any answers for them going forward. The clear lesson is to get out in the field to establish relationships so the business folks and others will come to you with their issues, problems and concerns. Engage in compliance town halls or other similar events, which can increase your exposure to your employee base. You can use social media as a two-way communication tool to virtually meet with people and engage with them going forward.

But more than getting out in the field to meet your customer base (i.e., the employees), be responsive to their concerns. Respond to emails, answer phone calls and take the time from your busy schedule to meet with people that drop by your office. Do not let the compliance function become the black hole where questions and issues go to die. Be responsive, and the customers of your compliance products and services will appreciate it going forward.

Near the end of the article, West offered another piece of advice for the CCO or compliance practitioner: More than simply staying calm and carrying on, she advises to keep your tone of voice the same when you pass along what you think needs to be accomplished. Then, follow up by telling them why it needs to be done to help to get their buy-in on the instructions you are providing.

As with many leadership lessons, Lt. General West provides some solid tips for both the CCO and compliance professional. Further, you can incorporate her communication and leadership ideas into your compliance program to help facilitate your relationship with your customer base. Finally, take a minute to remember what day it is and why we honor it.

This article was republished with permission from Tom Fox’s FCPA Compliance and Ethics Blog.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business advice, legal advice or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The author gives his permission to link, post, distribute or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.


Thomas Fox

Thomas Fox has practiced law in Houston for 25 years. He is now assisting companies with FCPA compliance, risk management and international transactions.

He was most recently the General Counsel at Drilling Controls, Inc., a worldwide oilfield manufacturing and service company. He was previously Division Counsel with Halliburton Energy Services, Inc. where he supported Halliburton’s software division and its downhole division, which included the logging, directional drilling and drill bit business units.

Tom attended undergraduate school at the University of Texas, graduate school at Michigan State University and law school at the University of Michigan.

Tom writes and speaks nationally and internationally on a wide variety of topics, ranging from FCPA compliance, indemnities and other forms of risk management for a worldwide energy practice, tax issues faced by multi-national US companies, insurance coverage issues and protection of trade secrets.

Thomas Fox can be contacted via email at tfox@tfoxlaw.com or through his website www.tfoxlaw.com.

Follow this link to see all of his articles.

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