As a profession, Chief Compliance Officers have to be aware of the old adage – “Be careful what you ask for, you just might get it.” Whoever crafted that saying, it applies right now to CCOs.
As more CCOs are given the “opportunity” to run a compliance program with the resources they request and the authority they need, all eyes will be on their performance. The profession has been clamoring for change and in many companies they are getting the change they want. The only question now is once the CCO gets what he or she wants, what do they do?
CCOs have spent so much time arguing and persuading corporate executives as to the benefits of a robust compliance program, they have to be careful to focus on the next step – delivering a compliance program that is capable of detecting and preventing code of conduct and legal violations.
If the Board and C-Suite understand how compliance program works, their expectations should be in line with the CCOs. However, if the Board and the C-Suite somehow believe that a compliance program will prevent all violations of the Code and the law, then they are in for a big disappointment.
CCOs have to educate the Board and the C-Suite on what exactly is reasonable to expect and how the compliance program is designed to achieve these results. Along the way, CCOs have to make sure they can show that compliance is a valuable contributor to the company’s bottom line.
CCOs know that it takes time to bring about change in a company, even with resources and authority to do so. Old ways have to be moved out, redesigned and forgotten. New approaches have to energize the company and be adopted as part of the corporate fabric. The last things any company wants to hear is a set of excuses as to why a compliance program did not work.
An important part of the CCO’s mission is to define the objectives and measure the results. CCOs have to avoid, like the plague, the easy and comfortable use of Happy Talk to keep everyone satisfied. Honesty and self-awareness means telling everyone what is occurring and how much progress is being made.
The profession is at an important crossroads. It is easy to argue that a compliance program failed because of the wrong structure and inadequate resources. CCOs have won that argument and are being given the authority and the resources. When that occurs, CCOs have to deliver and they must do so quickly and effectively.
Luckily, the compliance profession is not avoiding the challenge. They understand the corporate political game and they know they must make an immediate impact. Professional organizations provide important support for the profession and there is a strong collaborative spirit among compliance professionals. Unlike many other professions, CCOs know, at this point, that they are in it together. Let’s hope that this attitude continues for a long time.