CCO’s Be Careful What You Ask For — You Just May Have It

by Michael Volkov

be carefulThe old adage has taken hold in the compliance field – “Be careful what you ask for, you just may get it.”

Compliance professionals are finally getting the respect they deserve.  They still have a long way to go.  General Counsels, Internal Auditors, Human Resource professionals are not going to accept the elevation of compliance professionals lying down.

The corporate world is filled with back-stabbing, intrigue and petty jealousies – don’t kid yourself to the contrary.  When one position rises, others are sure to be jealous or want to see failure.

CCOs have to ignore the pettiness of he corporate world.  They can always soothe themselves by thinking it could be a lot worse – they could be in academia, where the old saying applies, “Competition in academia is so vicious because the stakes are so low.”

For CCOs, the stakes are large.  CCOs have been arguing for years for more authority, resources and independence.  They are slowly getting just what they asked for.  Now is the time for CCOs to deliver.

Donna Boehme, a champion for the compliance profession, has written a terrific article available here, outlining important steps that every CCO should take to help instill an ethical culture.  (Here)

Just what are they supposed to deliver?    I hope everyone understands that CCOs are not guarantors of compliance.  They create and implement processes that are designed to minimize risk – the key word being “minimize,” not eliminate.

On the flip side, CCOs are promoters of an ethical culture.  They are politicians, evangelists, financial analysts, and everything they can roll into their job description.  They have to spread the word on corporate careful5

The fact is that CCOs have a positive message and they should stick to it.  People respond well to positive messages.

The same goes for a company’s internal politics.  Senior executives, managers and employees want to believe in their company; they want to embrace ethical conduct.  Everyone wants to “do the right thing.”  (Be careful of those who do not, they are sure to bring you down – they are the dark side of corporate governance).

The CCO’s message should tap into this powerful need in the corporate gestalt.   The positive message is the one that brings about positive financial results, greater sustainability and improved morale.  Each of these factors contributes to the other.

In the end, the CCO is part politician, part cheerleader, and part psychologist.  They have a schizophrenic task – on the one hand, they promote a positive message; on the other hand, they enforce the Company’s code of conduct; and on yet another hand, they have to prevent an enforcement action from a breakdown in compliance controls.

CCO’s asked for authority and they have it (or are getting it).  They are still fighting for the be careful6resources they need.  That will come – companies have no choice.

The real test for CCOs in the next five years is straightforward – they have to produce.

How and what they produce, is the next issue to be defined.

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

Written by:

Michael Volkov

The Volkov Law Group on:

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