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Home Compliance

What Does the “Good News Cocoon” Mean to Business & Compliance?

by Richard Bistrong
April 3, 2017
in Compliance, Leadership and Career
Monarch butterfly cocoon on branch

Keeping Your Ears Open to Hear What’s Broken

Leaders are expected to facilitate the organization’s success; that’s why they’re paid the big bucks. But there are too many layers separating executives from front-line staff, it’s rare for them to hear firsthand where key ethics and compliance issues lie. Richard Bistrong discusses the “good news cocoon” and how to learn what you don’t know in order to fix it.

This piece was originally shared on Richard Bistrong’s blog and is republished here with permission.

Recently, I had the pleasure of engaging with compliance and business leaders in Europe and Asia. It’s an honor to be traveling again and to hear about ethical and compliance challenges from those who work in the middle of risk, as well as from leaders who are tasked with supporting the commercial workforce in how they address issues of ethics, integrity and values.

Over a nice walk along the Neckar River in Germany, I thought about the need for business leadership to take a more active role in what we think of as “ethics and compliance” issues. And that’s more than just internet quotes and wall posters – what I am speaking of here is dialogue, engagement and action. It’s about business leaders making sure that commercial teams understand the “definition of success,” which addresses not only compliance issues, but matters around commercial objectives, strategy and incentives.  Furthermore, when I reference “business leadership,” I mean executives with P&L responsibility.  In this context, compliance needs and issues are addressed and embedded through business leadership and action, as a part of strategy, objectives and incentive planning, as opposed to “compliance from afar.”

It’s a call for leadership dialogue and engagement, not only in how goals get executed via a disbursed commercial workforce, but also around how leaders demonstrate care for their teams as individuals who might work in places where “culture appears to conflict with the rules,” and where there could be risk that people start to look at their environment, as opposed to corporate leadership, for behavioral cues.

If you are a business leader and like the concept but are not sure where to start, or if you’re a compliance leader looking for some coaching, there’s a great article in the Harvard Business Review’s March-April 2017 issue, Bursting the CEO Bubble, by Hal Gregersen. But don’t be dissuaded by the title, as the CEO challenge which he addresses is “every leader’s dilemma,” and those issues surround what happens when there are “too many layers between yourself and the front lines of business.” And what lies among those layers is “what you don’t know,” hence my challenge to business leaders – CEOs included – to get there.

While I often speak about the “cocoon of corruption,” as discussed in a prior interview with Jamie-Lee Campbell, Gregersen talks about the “good news cocoon,” the phenomenon business leaders often encounter in which they don’t receive news of challenges, problems and shifts in the environment because they haven’t demanded it or “because they don’t know how to ask for it.”

So back to where to start: It’s that image of vulnerability, humility and humanity, where business leaders are willing to acknowledge both that they might not always get it right, even with good intentions, and that their “definition of success” might look confusing in some regions. But that vulnerability needs to be coupled with a call to the workforce where confusion reigns to speak up about it.

In many parts of the world, there’s going to be some inevitable tension between objectives, ethics and compliance, and that discord needs to be resolved. So, as Gregersen shares, by “projecting an approachable attitude that inspires other people to speak up,” leaders will be exposed to a wide variety of constituencies and differences of opinion. That reduces the power and probability that employees will attempt to unpack those conflicts on their own and instead will reach out to their leadership for solutions. And that’s true teamwork in always attacking what might be weak points in the system.

I ask, when was the last time a business unit leader in your organization met with the commercial workforce – especially those working in remote, thinly supervised locales, and asked “if you were in my job, what you be focusing on?” Or Gregersen’s call to probe, “what’s broken?” He shares the work of one CEO who goes with his senior leaders on “global listening tours looking for weak strategic signals.” When leadership sets out to “be on the lookout” for times when they are wrong and embrace the “notion of being wrong,” then instead of transmitting messages, they will “switch over to receiving them.” That’s getting to what you don’t know and demonstrates leadership that not only embraces ethics and compliance practices, but is willing to dig into how that all looks from the people who work in the middle of risk and where trouble is most likely to occur.

Gregersen makes a great point: most executives generally don’t get paid “for being mistaken,” and when “leaders are determined to have all the answers, they stay within the bounds of what they know.” Thus, I think business leaders would be well advised to follow Gregersen’s simple solution to “get out of the office,” and “spend more time being wrong, being uncomfortable and being quiet.”  If you do, “the odds quickly decline that you’ll stumble upon what you didn’t know” and just as important, “before it’s too late.”


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Richard Bistrong

Richard Bistrong

Richard Bistrong, CEO of Front-Line Anti-Bribery LLC Former FCPA Violator and FBI/UK Cooperator; Anti-Bribery Consultant; Writer & Speaker Richard Bistrong spent much of his career as an international sales executive in the defense sector and currently consults, writes and speaks on foreign bribery and compliance issues from that front-line perspective. Richard’s experience included his role as the Vice President of International Sales for a large, publicly traded manufacturer of police and military equipment, which required his residing and working in the UK. For well over 10 years, Richard traveled overseas in his sales responsibility for approximately 250 days per year. In 2007, Richard was targeted by the U.S. Department of Justice in part due to an investigation of a UN supply contract and was terminated by his employer. In that same year, as part of a cooperation agreement with the DOJ and subsequent Immunity from Prosecution in the United Kingdom, Richard assisted the United States, Great Britain and other governments in their understanding of how FCPA, bribery and other export violations occurred and operated in international sales. Richard’s cooperation, which spanned three years of covert cooperation and two years of trial preparation and testimony, was one of the longest in a white-collar criminal investigation. In 2012, Richard was sentenced as part of his own plea agreement, and served fourteen-and-a-half months at a federal prison camp. Richard was released in December of 2013. Richard now consults, writes and speaks about current front-line anti-bribery compliance and ethics issues. Richard shares his experience on anti-corruption and ethical challenges from the field of international business, reflecting on his own perspective and practice as a former sales executive and law enforcement cooperator. Richard currently consults with organizations through his company, Front-Line Anti-Bribery LLC, and welcomes the opportunity to exchange and share perspectives on real-world anti-bribery and compliance challenges.  Richard has shared his experience, via keynotes and panels, with the OECD, World Bank and International Anti-Corruption Academy, as well as major multinationals and leading academic institutions. Richard can be reached via his website www.richardbistrong.com  or email richardtbistrong@gmail.com and he frequently tweets on #FCPA & #compliance via @richardbistrong.  Abstracts on his consulting practice can be found on his website. Richard is also a Contributing Editor to the FCPA Blog at www.fcpablog.com.

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