This article was republished with permission from Michael Volkov’s Corruption, Crime & Compliance.
“Honesty: the best of all the lost arts.” – Mark Twain, 1902
I may be getting cynical in my old age, but honesty is a rare thing these days. It seems to be getting more difficult to find honest people, especially when it comes to business. Each day we read about another scandal involving another fraudster, corrupt politician or criminal motivated by greed.
Corporate ethics and compliance, however, appears to be gaining steam as an important part of every company. Much of the success of a corporate ethics and compliance program depends on the “message” from the company’s CEO.
A CEO who is committed to ethics and compliance does not guarantee compliance. But a CEO who is dishonest or ignores ethics and compliance is almost certain to bring about a corporate culture filled with risks and possible corruption and misconduct.
It is a breath of fresh air to meet and observe a CEO who “walks the walk” rather than just talks the talk. Too many Chief Compliance Officers are satisfied with a CEO’s statement of commitment to ethics, whether it is in a newsletter or made at a corporate meeting. A statement is only just a small piece of the puzzle. It is one act – and it is not enough even if it is made every week, month, quarter or even every day.
CEOs establish a corporate culture in their companies when they act with a commitment to ethics and compliance. Everything they do must demonstrate their commitment to ethics and compliance. That is the only way they can bring honesty to the table.
Senior management, mid-level managers and employees know honest people when they see them. A CEO who is committed to integrity will have no problem getting the message across so long as he or she acts in accordance with that principle.
The CCO’s challenge is to promote and communicate the CEO’s actions and commitment to ethics and integrity. A monthly newsletter is not enough, a video statement before a training program is not enough, and a brief statement of commitment at an investor meeting is not enough.
A CEO’s actions have to be transparent, publicized and communicated through all available channels. Sometimes the best way to spread the word is to watch as employee word of mouth communicates the message – the CEO’s actions and his or her words show that the CEO “walks the walk.”
A CCO who has the benefit of a CEO who walks the walk has a significant leg up in creating an effective compliance program in comparison to the CCO who struggles to elicit words and actions from the CEO that demonstrate ethics and integrity.
As the old saying goes, actions speak louder than words.
A CEO who acts with integrity and ethics and talks about ethics and integrity is the best insurance policy that a company can have to ensure compliance.
We all look to our leaders to emulate the personality traits we admire and want to see in ourselves. A CEO who exemplifies ethics and integrity does that in a powerful and effective way – for CCOs, the greatest blessing they can have in building an effective compliance program is a CEO who acts with ethics and integrity.