The mental health crisis among ethics and compliance professionals has remained largely unspoken despite its prevalence. Drawing on personal experience and CCI’s 2025 report on compliance officer well-being, an anonymous ethics and compliance leader examines the misaligned reporting structures, competing priorities with legal departments and professional isolation that create conditions where toxicity thrives while resources dwindle — and yet, why practitioners remain dedicated to their mission even as organizational structures systematically undermine their effectiveness and wellbeing.
Editor’s note: The author of this essay has been granted anonymity by our editorial board given their sensitive role in the defense industry.
Finishing CCI’s “2025 Compliance Officer Working Conditions, Stress and Mental Health” report felt like walking out of a therapist’s office after a good cry. In those pages, I found a virtual transcript of the same poignant conversation I’ve had with colleagues 20 times before in my career, but what surprised me — and what led me to write this reflection — was not the truth of the findings but the secrecy with which they were shared among my colleagues.
What rightfully should have been a boisterous online rendition of the “Hallelujah” chorus sung by the ethics and compliance community was reduced to a few verses of “Everybody Hurts” by R.E.M. whimpered in secret.
This essay is an attempt to cut through that hush. As one responsible for an ethics and compliance program at a global defense company who is riddled with the mental health concerns verified in this report, I put pen to paper to exemplify these problems, theorize why our professional angst exists — and suggest why we are afraid to discuss it.
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Those of us who believe in the cause of ethics and compliance take great satisfaction from our conviction that we are empowering people. Contrary to the stereotype (“Compliance is about ‘No.’”), practitioners in our profession believe that by creating positive, supportive organizational cultures in which rules and processes apply equally to everyone, we are enabling both individual and collective thriving. In an ethical and compliant company, employees come to a workplace where they are valued, where risks can be taken, where innovation can blossom, where people can make the most of their lives and from where they can go home with a clean conscience.
… [T]his reporting relationship isn’t merely ineffective; it is inherently combative, and not only in those tense, high-stakes situations where the perspective of my function is distinctly and appropriately different from that of the chief legal officer (and yet is curtly and summarily overridden). Disagreement between E&C and legal is healthy and natural. It should also be routine and helpful to the business, but the reporting relationship curtails any constructive conflict immediately — and to the benefit of no one.
As drivers of positive change, the people who work in the ethics and compliance profession are smart, brave and purpose-driven. Perhaps most distinctively, they are optimistic (the best cynics are) and relational. By “relational,” I don’t simply mean that they are amiable and have a high emotional intelligence but that they can make connections between concepts, actions and time horizons that are often invisible to others — a skill that works best in safe environments.
However, as a profession, we are also insecure to the point of embarrassment. Much like Charlie Brown running to kick the football that Lucy will certainly pull away, we work for organizations and within reporting structures that ask us to do great and impossible things, only to undercut our efforts again and again.
Through this routine, we grow to understand that we are vulnerable in our roles and yet are expected to carry on anyway. It is the constant vulnerability, combined with our employers’ apparent need to remind us of it, that leads to the anxiety and depression highlighted in the report.
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My primary reporting relationship to the chief legal officer is the source of this vulnerability, and CCI’s report confirms that I am not alone in this view. The study reports that, “COs who report to the legal department or General Counsel were the most dissatisfied. A combined 27% of those reporting to the GC rated that structure as ineffective — that’s more than double any other structure.” (This organizational construct is so common in the defense industry that alternatives are no longer discussed.)
To be clear, this reporting relationship isn’t merely ineffective; it is inherently combative, and not only in those tense, high-stakes situations where the perspective of my function is distinctly and appropriately different from that of the chief legal officer (and yet is curtly and summarily overridden). Disagreement between E&C and legal is healthy and natural. It should also be routine and helpful to the business, but the reporting relationship curtails any constructive conflict immediately — and to the benefit of no one.
Where the legal department at my company exists exclusively to identify and mitigate risk, the ethics and compliance role is refreshingly and compassionately more ambitious and seeks to do far more good for both the employees and the company. I do not know a single ethics and compliance professional anywhere who believes that the job starts and stops with risk — as our lawyers do — and this is where the tension in our reporting relationship begins.
Where I seek to educate, to engage proactively with stakeholders, to find root cause with hopes of preventing future misconduct, to create processes with the end user in mind, to hire or develop a professional team, to implement technology, to assess the organization we service, I am told explicitly that I am pursuing more than someone in my role should and that in doing so I am creating potential legal risks that must be avoided. The message is clear: There are penalties for operating outside the risk box we’ve put you in.
The mission of my legal organization and the mission of the ethics and compliance profession are at odds with one another, and when you are, moment to moment, strategically at odds with the person who signs your paycheck, insecurity and anxiety inevitably follow.
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The effect of this reporting relationship is seen clearly in the lack of resources dedicated to ethics and compliance. I have approximately a third the staff and resources of an “average,” barely adequate E&C program because my funding is in direct competition with the staffing and resource needs of lawyers, a profession with a different mission, in a different employment market.
Every year, the chief legal officer must resolve questions like: with the increases available this new year, should I give two $300,000 lawyers a raise to retain them, or should I create an E&C position to do the most basic work of that function? Should I hire a junior attorney to keep the big program happy, or should I pay for the software license that brings E&C out of the dark ages? Guess which options are chosen.
Within this reporting relationship, ethics and compliance is repeatedly reminded that it is not as valuable, nor as beneficial as the cliché rhetoric of senior leadership implies, but at the same time, the high expectations nailed to E&C are unwavering.
I have spent more than 10 years fighting unsuccessfully to obtain the tools needed for my function — and the past three months suffering the professional embarrassment resulting from the failures of my existing systems. I just spent three years begging for suitable pay for exceptional team members and then six months trying to rehire their positions after they were lured away.
It is explicitly clear that I am accountable for — that I personally will suffer the consequences of — a compliance failure in the business, even if the resources for my function remain manifestly inadequate for purpose and substandard by any measure. Perhaps worst of all, it is in this environment that when a serious issue arises, I have been urged to “make it go away.”
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What I have described so far — and what is confirmed by the report — is a misaligned reporting relationship of two functions that encourages the dominant one to devalue the other with no institutional recourse provided. The subordinate function is saddled with all the expectations, limited support and deficient funding but with the promise of sole accountability when results go inevitably wrong. Toxic circumstances like these cause practitioners in E&C to experience the vulnerability we feel, but what amplifies these emotions is that we experience them in almost total isolation.
It is isolation that makes anxiety and depression acute. Exactly to whom can we say, “this isn’t working” or “I can’t do this” or “the compliance program that I run is hovering on the edge of malpractice” without risking the end of our careers? E&C practitioners have neither the colleagues, nor the leadership, nor the “work friends” (from whom we often must draw sharp personal boundaries) who can play the part of empathetic listener, much less serve as an advocate for positive change.
Day to day, we make our living respecting confidentiality and practicing silence, but this also means that we are in roles that have conditioned us against transparency and openness with almost anyone about what has gone wrong, what might go wrong or even why wrong happens.
Housed within the legal department, we are vastly outnumbered by those who dominate our work; in my case at a ratio of about 7:1. We take our lumps unconnected with anyone who understands or who can help, only to head home and share our concerns with our spouses and children, our basement bartender or nobody at all.
And yet we carry on. For better or worse, we seem to stick it out, don’t we? Maybe we just love the struggle, the fight against insurmountable obstacles. Maybe waging a losing war fits with our self-image. Oddly, miserable as we are, I have never known an ethics and compliance professional to leave the field entirely for any reason other than retirement. Perhaps this is why we’d rather not talk openly about our vulnerability and isolation or the anxiety and depression that results: We desperately want to keep going no matter what.
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If my sharing these thoughts in this forum helps to spark an open and constructive discussion within our field, and if perhaps that leads to some improvement in the roles to which we are so dedicated, my hope is that the final few years of my career will be filled with security, certainty, achievement, support and connection. Thank you for being here.
