Five New Year’s Resolutions for the CCO

This article was republished with permission from Michael Volkov’s Corruption Crime & Compliance.

I try to avoid New Year’s resolutions because I usually do not stick to them.  But the process is good as a way to organize your focus and energy.

For Chief Compliance Officers, it is more important than ever to re-examine where they are professionally and set some goals for the year.  CCOs are quickly rising to the top of the professional ladder.  There is a lot at stake because corporate boards, senior management and the government are all focused on what CCOs are doing and how they are doing it.

Given the stakes, CCOs have to develop their own resolutions specific to their situation.  For the profession as a whole, here are some suggested resolutions:

1. Educate the Board – CCOs are being given an opportunity to demonstrate their value to an organization.  It is not enough to just keep the company from getting into trouble – there has to be a value-added benefit.  A commitment to ethics, a consistent message of ethics and compliance, and the development of a culture of ethics is a minimum requirement.  The Board has to be part of this process – the message must come from the Board and with the Board’s full support.  If the Board lacks commitment, then the CCO will have a tougher time building the program.

2. Collaborate and Build Alliances – CCOs depend on support and collaboration from other parts of the organization.  It is essential that CCOs develop a positive message, use their interpersonal skills to reach out to other constituencies in the organization and develop a compliance network of supporters.  A CCO will not succeed without internal alliances and commitments from other parts of the organization.

3. Honesty, Not Happy Talk – CCOs will not succeed without being honest.  That does not mean you have to become a doomsayer, but it is important to be an honest broker.  Too many CCOs report to their Boards with “happy talk” presentations as to the accomplishments of the ethics and compliance program.   Everyone loves a pat on their back, but there is a time and place for that.  CCOs have to be honest about risks and have to encourage an honest dialogue at the Board level, with senior management and with other compliance stakeholders.

4. Leverage Your Resources – CCOs do not have enough resources.  Every CEO knows this.  If educated on the issue, a CEO should make sure that enough resources are given to the CCO.  One of the best ways to demonstrate the value of compliance is to show senior management how compliance maximizes the use of resources.  CCOs have to be creative and string together some of their operations.  That is a fact of life.  Data analytics and other solutions should be used and allocated based on a risk ranking.

5. Communicate In the Organization – Too many CCOs like to sit behind their organizational wall and toil away at compliance issues.  That is a recipe for disaster.  CCOs have to be politicians (which I mean in a positive way).  They have to communicate a message by taking advantage of social media, internal communications systems, training and outreach meetings.  Technology has brought people together in many ways.  There still is a value to face-to-face contact at training, sales meetings and outreach sessions.  CCOs need to meet with as many people in the organization as possible; if they can travel, they should take advantage of an opportunity to meet with other offices and divisions.