Chief Compliance Officers are the rising professional stars in the corporate employment landscape (along with IT professionals who have practical perspectives). The profession is at an important test – where will the profession go from here and what steps do CCOs need to take to prepare for these challenges?
I always say that CCOs are a confident group of people. They are committed to not just being complaint with the law but they understand the importance of promoting ethics in an organization. A proposed transaction, for example, may be legally compliant but they ask the next question – is the proposed transaction consistent with our ethics?
So what should CCOs do to take their profession to the next level? CCOs have a unique opportunity to create and guide the development of their profession. Here are some suggestions on how they can move the profession along:
1. Adopt a Professional Code: CCOs need to adopt some basic principles that guide their work. It is not hard to do but it is hard to get everyone to agree on a common set of principles. For example, how do you define doing the “right” thing when that concept is hard to define in specific situations, especially when unethical conduct can occur in so many shapes and forms? Still, there is a need for ethics and compliance professionals to get together and start to hammer out some guiding principles. Joe Murphy, a leader in this area, has done a lot of work to enhance the professional qualifications and he has provided an important starting point for these discussions.
2. Promote Educational Programs: Where do professionals go to school to become training ethics and compliance professionals? Law schools, business schools and other programs provide limited focus on the importance of ethics and compliance training. The SCCE and ECOA have provided critical training programs but more is needed. An all out effort has to be made to push universities, colleges, graduate schools and other educational institutions to work with SCCE and ECOA leaders to develop meaningful educational programs.
3. Increase Ethics and Compliance Research: The ethics and compliance industry is in dire need of real research to understand ethics and compliance functions and develop meaningful best practices and policies. Too much of the research is not rigorous and cannot withstand basic social research and study design standards. As a consequence, research is subject to constant critical attack.
4. Communicate Practical Solutions: Building on education and research, CCOs need to develop an agenda that pushes real and practical solutions. Not everything is black and white, right or wrong, and CCOs have to recognize that corporate decisions and risk-taking often involve trade-offs. CCOs have to be a part of the practical solutions, not the naysayers who embrace a holier than though approach to business issues. This practical policy approach means that CCOs can voice a concern but in the end they have to recognize that their job, like everyone else’s depends on the ability of a company to survive in the marketplace.
5. Be True to Your Values: Even while I urge CCOs to adopt practical solutions, there are certain lines in the sand that cannot be crossed. For example, can you imagine how a CCO would have handled the GM safety issue? There is no way that a CCO committed to “doing the right thing” would ever allow GM to ignore the safety issues and permit GM to continue selling dangerous vehicles. The GM scandal would look very different today if there had been an independent and empowered CCO.