On this day in 1961, just six weeks after having been sworn in, President John F. Kennedy issued an executive order establishing the Peace Corps. It proved to be one of the most innovative and highly publicized Cold War programs set up by the United States. During the course of his campaign for the presidency in 1960, Kennedy had suggested that a new “army” should be created by the US, whose force would be made up of civilians who would volunteer their time and skills to travel to underdeveloped nations to assist them in any way they could. By any measure, the Peace Corps has been a success in terms of helping to “win the hearts and minds” of people in the underdeveloped world. The program continues up until this day.
This new idea, which may not have radically changed the world but is one small step in making it a better place, is the theme for today’s blog. Recently in a Harvard Business Review (HBR) article, entitled “Bright, Shiny Objects and the Future of HR”, John Boudreau and Steven Rice wrote about how “HR leaders tend to reach for the shiny objects of their trade – cool new research and insights about talent management and leadership.” They posed the question “How can they choose the best of these and integrate them into a coherent system?” While the focus of their article was a corporate Human Resources (HR) department, I thought about their four-part answer in the context of a Chief Compliance Officer (CCO) or compliance practitioner.
Get the Big Picture
Their first insight was to “get the big picture” which means that you need to determine a “reliable way to discern the big picture – the conditions and business imperatives that create the context for their choices.” To do this they cited to examples of asking lots and lots of questions to managers around the world. Recognizing this is always a risk to have people tell you what they are thinking, the company was able to use this technique to help drop siloed behaviors and thinking.
For the compliance practitioner the key point is to work and interact with the business folks to understand what is not efficient about your compliance procedures. When was the last time you as the CCO sat down with senior managers and asked ‘How are we doing’ and more importantly ‘What could we do better?’ If it turns out compliance is too centralized in your corporate headquarters, what can you do to decentralize it and put it out into the field?
Spot the Valuable Insights
Never forget as a CCO your customers are the company’s employees. The authors noted, “A series of communication problems with a key customer had resulted in missteps and quality concerns. The obvious, traditional solution might have been to focus on the salespeople who met the customer.” An understanding of what your customer needs allows you as the compliance practitioner to “Seek out – and take in – the latest and greatest management ideas and connect them to what is pivotal in the organization. Tying together values, performance assessment”, and this should be a key goal for any CCO.
Moreover, one of the universal criticisms of the compliance function is that it does not collaborate across business units and job functions. So think about “the idea that organizations are networks, not just hierarchies and business units.” This can help to “encourage everyone in the organization to be slightly more collaborative; collaboration had to be seriously enhanced in the few spots where it would make a crucial difference.” As the CCO you can then work on or deliver resources to those areas, whether geographic of business line oriented, which are lacking in this collaboration with the compliance function.
Apply with Care
The authors noted this next area must ensure integrating your insight with sensitivity. They explain that major innovations “must be purpose built. Juniper has explicitly moved away from a “best practice” approach. Instead it strips a promising practice down to its kernel of insight and then expands that insight into work experiences that are right for the company’s unique climate, brand, and business objectives. This allows and requires the application to have impact in connection with other components, leading to a greater payoff.”
For the compliance professional this means working with your internal customers to prototype an idea “in some fertile area of the organization is a valuable way of working out the necessary synergies. It also offers proof of concept through experience. You can’t just tell people about a great idea and expect them to pick it up and run with it; they need to see and experience its value.” You are always going to have compliance champions in selected areas of your organization. If you have a difficult or challenging idea, which at the end of the day will improve efficiencies, you should move forward, to provide a pilot and then use that positive experience to role out on a company wide basis.
Aim for Business Impact
The authors suggest you should rethink how you measure progress and impact. The goal is to “ensure that it keeps people’s focus on what is most pivotal for the business. Assessing pivotal impact is a critical step toward further progress. Measurement becomes a forward-looking learning and improvement process rather than a backward-looking declaration of triumph or failure. Metrics and signals along the way tell you what’s working and what isn’t, where to recalibrate or ask more questions. You need the mindset – and the stomach – for experimentation, revision, and occasional missteps.”
A good example is data analysis. Here you may need to look at data through a different lens. Ever thought about employee participation in a 401K as an analytical data point about how they might feel about your company; including its culture, values and ethics? The key insight is to map the logical connections between the compliance initiative and your business outcomes. Make your compliance initiative a business differentiator and “Focus on what can be measured along that path, and extrapolate where you can’t measure precisely. That’s exactly what every other management discipline does.”
Failing to innovate and improve your compliance program is not an option. Every Deferred Prosecution Agreement (DPA) from the past 10 years has included language that requires the company to take account of industry, technological and compliance innovations. One of the most unique insights which the authors had was to “fall in love with the problem” and not the solution. This is because if you do so, you will let “the challenge soak in, studying it from various angles, and understanding it more deeply. Rather than hastening to narrow the scope of your decision and the options under consideration, you remain receptive to additional, possibly better ones.”
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