Hiding Out: The Danger Of A Disconnected CCO

by Michael Volkov
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complianceofficersWe all remember the fun we had as children playing hide-and-seek.  It was a great game and those of us who are parents have passed on the rich tradition associated with that game.  Unfortunately, in our kids’ world, I am sure it has been turned into an “RPG” (Role Playing game) which is played online with hundreds of thousands of players around the globe.

When it comes to compliance, CCOs have to be careful not to fall into the trap of “hiding” in the corporate organization.  For one thing, if a CCO hides, no one will come and “seek” them out.  It is one way to ensure that a compliance program will fail.  A disconnected CCO is a recipe for disaster.

The risk of becoming a disconnected CCO is real.  Compliance officers love their processes, their programs and their measurements.  It is easy to become enamored with the world of measures, graphs and colored bars as part of your “compliance dashboard.”  They are important functions and enable the CCO to measure the performance of the company’s compliance program.

The danger is when a compliance department becomes all about the numbers, the graphs and the color dashboard.  In such a situation, the CCO becomes disconnected from the most important part of compliance – the people.compliance

I do not mean to be trite but CCOs need to embrace the company people.  The most important skill that a CCO needs, and for that matter everyone in the business world needs, is the ability to relate to people.  The term “relate” means more than simply understanding what the people say or need.  There is a lot more to relating to people than just “understanding” them.

A connected CCO has to have interpersonal skills – the ability to listen and to motivate.  Both of these skills go hand-in-hand.  Listening is the ability to empathize and understand the person’s perspective and motivations.  Bringing these concepts together, the CCO can then develop ways to motivate management and employees to do the right thing – to act consistent with the cultural objective of the CCO.

Too often, I see a compliance department which is disconnected.  The CCO hides behind his or her processes, graphs and color codes.  When the CCO walks into a room and the employees joke is “Uh Oh, here comes the sheriff,” that is not a good sign.  The response indicates that the CCO is perceived as an enforcer of the law and company policies.  The CCO is hiding behind a single aspect of his or her job.  That perception needs to change and it is up to the CCO to create a new perception.

complcomm4Let me offer a different model.  A CCO who is connected will have regular interactions with all of the relevant constituencies: the board, the CEO, senior management, mid-level management and employees.  If necessary, the CCO should consider his or her own “listening tour,” in order to develop interpersonal connections with people, to break down the perception of the CCO as an “enforcer” and develop a reputation as a fair, problem-solver.

The more interactions the CCO has, the more the CCO can motivate and ultimately persuade the company’s officers and employees to adhere to an ethical culture.  A CCO who is disconnected will have missed an opportunity to succeed.  Looking at graphs and color codes is not the way to motivate and persuade employees.  CCOs (and all of us) need to step away from the computer screen and remember the importance of human interactions.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Michael Volkov, The Volkov Law Group | Attorney Advertising

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Michael Volkov
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