The Father of Texas and Leadership in Compliance

Thomas Fox - Compliance Evangelist
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Today we celebrate leadership, which comes from a different place than we usually see. On December 27, 1836, the Father of Texas, Stephen F. Austin, died. Most people think Sam Houston was the father of this great state but it was the person for whom our state capital is named. Austin was the man who led the colonization of Texas in the early 1830s and was one of Texas’ earliest political leaders. He was appointed by Sam Houston as the first Secretary of State for the Republic of Texas but only served two months before his death at the age of only 43. On his deathbed, Austin’s last words were “The independence of Texas is recognized! Don’t you see it in the papers?…” Upon hearing of Austin’s death, Houston ordered an official statement proclaiming: “The Father of Texas is no more; the first pioneer of the wilderness has departed.”

I thought about Austin’s early leadership in the colony of Texas, when I read a recent article in the Houston Business Journal (HBJ), entitled “10 leadership skills for entrepreneurs”, by Gregg Swanson. While Swanson’s piece was designed to help an entrepreneur understand “how to handle a demanding situation while leading others”; I also found his ideas were useful for the Foreign Corrupt Practices Act (FCPA) compliance practitioner as well. I have adapted his concepts aimed at entrepreneurs to Chief Compliance Officers (CCOs) and compliance practitioners.

  1. Assemble a committed team

Even if you are a solo in compliance at your company, you will need a compliance team. If you have the resources to hire others, Swanson advocates for you to “Put an end to socializing methods and selling talent. Instead, focus on building a team that is committed and possess the skills to be successful.” Regardless, every CCO works with a leadership team and others in the organization. You must get them committed to compliance.

  1. Communicate without limitations

Here Swanson recognizes that “Solid communication with other coworkers is essential, if the business wants to be successful. After all, if your team doesn’t communicate, how can they know what is expected of them?” Certainly this is an important part of a CCO’s role in dealing with others in the compliance function. However I also think it has much wider implications for the compliance practitioner. Communicating not only what is expected but also how and why compliance will help the business unit is critical to the success of any compliance officer.

  1. Make your business mission statement clear

Swanson writes, “An entrepreneur may assume clients and coworkers understand his or her objectives. In many cases, they probably do. As part of your approach to leadership, ensure that you revisit the mission statement with them to ensure that it’s correctly understood.” The same holds true for the CCO or compliance practitioner. You must make the compliance mission statement clear going forward.

  1. Reveal true genuine leadership

For an entrepreneur, Swanson believes that “You’ll never be that great leader simply by emulating the actions of others. But you can learn from the success and failures of others. Your employees are going to believe you more when you are dependable and real.” This is true for the CCO or compliance practitioner, only 100 times greater. If you are sitting in the CCO chair on your way to bigger and better things in the corporate world, you will never be taken seriously as a compliance practitioner. Worse, your company’s compliance program will not be taken seriously and the results will probably bear this out.

  1. Identify all of your barriers

Swanson wrote, “Most entrepreneurs believe that they are working towards their ambitions and goals. There’s nothing wrong with this. But a thoughtful leader will be the individual who takes the time to identify his or her own shortcomings.” In compliance, there are always course corrections that need to be made. This is a basic premise of any best practices compliance program.

  1. Build a flexible team and provide them with the right direction

Swanson considers it is critical when you are an entrepreneur trying to raise a successful team, to be “flexible with your team members as they define the function of things, influence the limitations or accomplishments they achieve.” For the compliance practitioner, the agility to move and adapt is a critical component of not only your compliance program but also your personnel. This is true whether they are your direct reports in the compliance department or you are using others outside the compliance department to facilitate your compliance program.

  1. Put some trust in your team

Here Swanson correctly notes, “In the business world, trust is essential. For the entrepreneur, there is a need to assist the growth of the group and to work past problematic periods. Strong leaders are people who others trust. Their assurance gives assurance to the group that everything will turn out fine.” Once again this prong is only amplified in compliance. No CCO can micro-manage as there is simply too much to handle. You have to learn to trust your team going forward. Yet you can also depend on technology to help verify that trust.

  1. Acknowledge people’s talent and give appropriate credit

While it may seem self-evident, Swanson reminds us that “One of the worst things you can do for your business is not to provide people with the credit they deserve. Many leaders can pull off an incredible presentation, but they always give credit to the people who helped them to shine.” As a leader in compliance, you need to give out credit to not only those on your compliance team but also others in your organization who may further your compliance efforts going forward.

  1. Motivate your team

As a lawyer who came into the compliance field, this was a concept I was not familiar with from my in-house experience. So it was good for Swanson to remind myself and perhaps others who may have begun in a corporate legal department that “You can’t become a great leader if your workplace is dull and you have a team that doesn’t care. You need to provide your team with moving demands. You can’t generate a great deal if a team doesn’t think based on their work.”

  1. Expect the unexpected

If there is one thing that all entrepreneurs should expect it is to expect the unexpected. Swanson said, “When you are an entrepreneur you need to have some kind of backup and safeguard in place that will help you to remain protected in extreme circumstances. With the current economic situation being incredibly harsh, it is important that you do what you can to avoid the pitfalls that can destroy a company.” Nothing could be truer for a CCO or compliance practitioner. Yet by moving from reactive to preventative and then prescriptive, you can get ahead of the curve and be ready to respond, quickly and efficiently.

As you move towards 2016 and consider innovation in your corporate compliance program, you would do well to contemplate these 10 leadership skills for yourself.

[View source.]

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.

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