Compliance always boils down to people and interpersonal relationships. No man is an island, and no one can go it alone in compliance. One essential requirement for effective compliance is the ability to engage colleagues and your audience.
Many senior executives are smart people –we all understand that. But too often senor executives embrace an interpersonal style of cheerleading. It allows them to appear to be on the “team” and prevent them from “rocking the boat.” Unfortunately, such an attitude prevents them from being a value add and problem solver for real management issues.
The flip side of the coin is senior managers who are perceived as careful analysts and thinkers but who, in reality, apply a pessimistic approach to corporate management. They live by the old adage – even a broken clock can be right twice a day. The pessimistic manager will always cite the negative possibilities and factors in any decision-making meeting, and then claim to be prescient if things fall apart.
Both of these types of managers – at the senior and the middle levels – will not help the company to implement an effective ethics and compliance program. The real key is to find the managers who fall somewhere into the middle. The trick is how to identify those managers and then rely on them to promote an ethics and compliance function in the business.
Effective managers have two important traits – they are good listeners and seek out information to understand an issue; and they are “action people.” Every organization can be easily divided into two categories of employees – those that want to “get things done” and those that like to “talk about” getting things done or defer to those who get things done.
These types of employees are easy to spot – next time you are sitting in a meeting and listening, focus on who is committed to getting things done, who is just attending the meeting, and who talks about getting things done but really does little in the end to accomplish a specific task.
A CCO’s livelihood depends on alliances and identifying the right candidates is critical to the ultimate success of a compliance program. Compliance officers need to identify the managers who will get things done and share a common goal or objective. Senior executives easily fall into these categories.
A “cheerleader” executive is unlikely to get things done and is more apt to be a talker who supports the efforts of others when politically convenient. A compliance officer does not need to spend a lot of time with these executives.
On the other hand, the nay-sayer manager will be unlikely to support compliance issues or go out on a limb, with certain exceptions. A CCO can channel or push the pessimistic manager to support a compliance position by citing possible negative scenarios that may result without compliance interventions. While the support of the pessimist may be helpful at some level, in the end, the pessimist is not likely to carry much influence in an organization because of credibility concerns.
When it comes to interpersonal relationships, CCOs have to be able to navigate political as well as personality issues to advance the compliance agenda. Relying on important alliances can be the ultimate predictor of a CCOs performance in the organization.
In the end, the CCO has to find the persuasive realist who displays strong interpersonal and leadership skills within a function or even across some functions. Every organization has a realistic star who carries weight – they are usually very senior and they are often very busy. CCOs have to find a way to align themselves with these key corporate leaders and gain their support.