Leadership in the Compliance Function – Do You Encourage or Stifle?

by Thomas Fox
Contact

There are many ways for a Chief Compliance Officer (CCO) to exercise leadership in not only the compliance function but also across the many disciplines in which compliance impacts in any corporation. In this Sunday’s New York Times (NYT), there were two diametrically opposite styles of leadership and management discussed in two articles. The first was found in the Corner Office Column, in an article entitled, “The Six Steps of Leadership (Plus Courage)” in which reporter Adam Bryant interviewed G.J. Hart, Chief Executive Officer (CEO) and President of California Pizza Kitchen. The second was found in the Off The Shelf Column where Fred Andrews, in an article entitled “The Military Machine as a Management Wreck”, discussed the recent book “Bleeding Talent” by author Tim Kane. I found that both of these articles provided some interesting techniques which the CCO or compliance practitioner could use in helping to set compliance as not only a key goal for any company, the articles also offered practical tips for day-to-day use in bringing the compliance perspective to the myriad of issues a compliance practitioner faces on a daily basis.

Hart related that his leadership style has evolved for the better because he has learned more patience and tolerance. He admitted that he used to “want things yesterday and would be very anxious about moving things along faster. But now I understand that tomorrow’s another day and that things will move along.” I have worked in industries where the joke was “If I want it today, I will ask for it tomorrow.” The reality, as put by Hart, is to think “about whether something really matters and how it will make a difference, versus thinking that everything matters and everything makes a difference.”

Hart said that the most important lesson he has learned is leadership qualities. He calls them “the six steps of leadership, surrounded by courage.” He believes that courage is always implicit because in any leadership role, you are stepping out, having the courage to be different “because you have to be different to be a leader.” Hart’s six steps are:

  1. Be the best you can be. Hart relates that you cannot “lead anybody if you can’t lead yourself. So you have to be honest with yourself about your good qualities, your bad qualities and the things you need to work on.”
  2. Dream and dream big. Hart recognizes that there is a “world of possibilities for yourself and for your organization.” You must have a dream and you must move towards it. This does not mean that you will “ever necessarily get there, but if you don’t dream, you’ll never even get started.”
  3. Lead with your heart first. Hart believes that your employees need to see that you are human and that you have a “human side” by showing people that you have compassion. It is all about being real. He states “It doesn’t mean that you don’t set expectations and standards. But if you lead with your heart, people figure out whether you’re genuine, whether you’re real.”
  4. Trust the people you lead. Hart recognizes that this may be the hardest trait for a leader to develop because this trait is all about letting go as a leader and allowing your employees to grow into their own style of leadership roles. Hart believes that only by allowing your employees to learn by making their own mistakes or falling down and picking themselves up and moving forward will they grow professionally. He believes that your role as a leader is to pick them back up.
  5. Do the right thing, always. Hart recognizes this is easy to say but as a leader this is where the rubber meets the road. In leadership Hart emphasizes that if your choice is following a rule or doing the right thing, you should do the right thing. He believes that this is particularly true “as it relates to people, and you genuinely believe in that person, sometimes it takes courage to do the right thing and give that person a second chance. Because we’ve all made mistakes and somebody picked us up.”
  6. Serve the people you lead. Hart believes that leadership is ultimately “about serving the people you lead.” It means that you should put a cause before yourself and to lead to make a difference. He ends noting that his role as a leader is to be “a catalyst for change, to create an environment where people can grow and prosper.”

In Andrews’ article, he wrote that the US military is now an “institution which is idiotic.” Andrews writes that Kane believes that “it dictates the jobs, promotions and careers of the millions in its ranks through a centralized, top-down, one-size-fits-almost-all system that drives many talented officers to resign in frustration. They leave, he says, because they believe that the military personnel system — every aspect of it — is nearly blind to merit.” This is in spite of the fact that Kane believes that “America’s armed forces are a leadership factory. He goes on to say that “former military officers are three times as likely to become corporate C.E.O.’s as their raw numbers would suggest.”

So what is the problem? Kane believes that “the root of all evil in this ecosystem” which is the Defense Officer Personnel Management Act, enacted by Congress in 1980. Andrews writes that this Act “binds the military into a system that honors seniority over individual merit. It judges officers, hundreds at a time, in an up-or-out promotion process that relies on evaluations that have been almost laughably eroded by grade inflation. A zero-defect mentality punishes errors severely. The system discourages specialization — you can’t expect to stay a fighter jock or a cybersecurity expert — and pushes the career-minded up a tried-and-true ladder that, not surprisingly, produces lookalikes.” Kane’s revolutionary idea to overcome this inertia is to create “an internal labor market for job assignments and promotions.” This change would allow a commander to choose a subordinate rather than having the Pentagon make the decision for him or her.

I have worked in both types of organizations. I can personally attest to the greater creativity and flexibility which led to greater innovation, where leaders viewed themselves as stewards such as Hart believes himself to be. I have also worked in military like organizations where the thing that got one promoted was be as similar to the next level up the rank and where innovation was definitely not viewed as a plus. The difficulty for a CCO may be that he or she works in such an organization. But even if a CCO or compliance practitioner does work in a military style organization, Hart’s six elements of leadership can be used to create a more vibrant, and ultimately successful, compliance program.

Written by:

Thomas Fox
Contact
more
less

Compliance Evangelist on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
Privacy Policy (Updated: October 8, 2015):
hide

JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.

Information Collection and Use by JD Supra

JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.

The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

JD Supra does not sell, rent or otherwise provide your details to third parties, other than to the authors of the content on JD Supra.

If you prefer not to enable cookies, you may change your browser settings to disable cookies; however, please note that rejecting cookies while visiting the Website may result in certain parts of the Website not operating correctly or as efficiently as if cookies were allowed.

Email Choice/Opt-out

Users who opt in to receive emails may choose to no longer receive e-mail updates and newsletters by selecting the "opt-out of future email" option in the email they receive from JD Supra or in their JD Supra account management screen.

Security

JD Supra takes reasonable precautions to insure that user information is kept private. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. However, please note that no method of transmitting or storing data is completely secure and we cannot guarantee the security of user information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us at info@jdsupra.com. In the unlikely event that we believe that the security of your user information in our possession or control may have been compromised, we may seek to notify you of that development and, if so, will endeavor to do so as promptly as practicable under the circumstances.

Sharing and Disclosure of Information JD Supra Collects

Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.

In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.

Links to Other Websites

This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.

Changes in Our Privacy Policy

We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.

Contacting JD Supra

If you have any questions about this privacy statement, the practices of this site, your dealings with this Web site, or if you would like to change any of the information you have provided to us, please contact us at: info@jdsupra.com.

- hide
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.