FCPA Compliance and Ethics Blog

December 23, 2014

Compliance Lessons from Santa

SantaWe interrupt our Avon blog post series to announce that a large man, with a white beard and red suit, will visit all on Wednesday evening. In honor of Christmas I want to write about some of Santa’s business lessons, which I have adapted from an article in the Houston Business Journal, entitled “10 Valuable Business Lessons from Santa” by Harvey Mackay. They are adapted for a Chief Compliance Officer (CCO) or compliance practitioner.

  1. The value of giving – Aside from milk and cookies or perhaps a carrot for the reindeer, Santa does not receive anything in return for all the gifts he shares with others. That is the real spirit of giving: not expecting anything in return. The joy of giving is reward enough. If that is not the definition of a compliance practitioner, I don’t know what is.
  2. Marketing and public relations – Would the far-flung work force know the CCO if he came to town because when Santa comes to town, everyone knows who he is. Santa’s image is everywhere and it’s my guess that he doesn’t pay a dime for the exposure. He attracts crowds wherever he goes. Businesses put him front and center in ads, decorations, even in big comfy chairs in prime locations in shopping malls. They practically beg him to show up. Can the same be said of your company’s CCO?
  3. He hasn’t changed his basic look – Steady and constant; those are two words that you can associate with Santa. Mackay believes that “More people can identify Santa than the president. His distinctive style of dress will never get him on a best-dressed list. But he doesn’t concern himself with that. His message has remained the same: a simple “Ho, ho, ho.” He doesn’t drive the latest model car. He is who he is and is content with that. What he does is more important than fad or fashion.” The same should be with your message of doing business ethically and in compliance.
  4. His attitude is contagious – Does your compliance function project a positive attitude, for Santa is “always positive, reminding young and old alike to be good for goodness’ sake. How he keeps track of who is naughty or nice doesn’t really matter — he encourages people to be their best. He rewards good behavior. And who doesn’t like to be recognized for trying?” Does your compliance function recognize employees for doing business the right way or simply penalize employees for stepping over the line?
  5. Santa respects deadlines – Mackay believes that reliability is important in the business world. He wrote that Santa “knows from one December 25th to the next that he has customers to satisfy. He is beholden to the calendar. It wouldn’t work to try to stretch it into January or February.” If it is one thing that drives business types crazy it is when compliance (or legal for that matter) does not meet deadlines that it has agreed to meet.
  6. Santa understands the value of tradition – This is one issue that compliance is not always the most sensitive to, whether it is through culture or language. If its language, call Jay Rosen at Merrill Brink to rectify that situation. If its culture, remember what Mackay intones, “Most of us have family or cultural traditions that bind us together. Businesses have traditions that customers anticipate. But have you ever noticed what happens when someone tries to change a long-held tradition? Santa knows better.”
  7. Customer service is high on his priority list – Never ever forget that it is business folks who pay our salaries so we need to give them some great customer service. When they have a question, answer it. If they phone rings, pick it up. If you get an email asking for assistance, respond to it. As Mackay notes, Santa “aims to please, and he rarely disappoints. I’m guessing he reads every letter written in a childish scrawl before he makes his list. If you happen to overhear a conversation between Santa and a child asking for the hottest toy of the year, you will likely hear a promise to do his best, but he has some other great ideas, too. He won’t promise what he can’t deliver.”
  8. Teamwork is central to his operation – The demands on Santa are enormous, yet he “understands that he can’t do it alone. A workshop full of elves and a team of nine little reindeer help him accomplish an impossible task year after year. I’ve heard there is magic involved, but I have no evidence to support it.” While you do not have to concern yourself with magic, use the corporate tools that are available to you. If you are resource constrained go to other disciplines and functions in the organization and work with them to further the goals of compliance.
  9. He epitomizes leadership – Mackay writes that Santa “leads his team, but he also guides the rest of believers toward the right path. He is consistent with his values. He is patient. He works hard. He is forgiving of mistakes and loves what he does.” Compliance is no different.
  10. He lives the wisdom of “love what you do and you’ll never work a day in your life” – Mackay affirms that you need to have a passion for what you do. He writes, “There can be no question that this guy wouldn’t want to do anything else. Santa couldn’t do what he has done for centuries without real enthusiasm for his efforts. Santa takes his work very seriously, but he doesn’t take himself seriously. He loves to laugh, make people happy, bring surprises, and spread good cheer. Santa understands that fun is good. a world full of serious problems, bringing a little happiness is a welcome relief. We can all do something to brighten someone else’s day.” I would hardily agree that you have to want to do compliance and if you have passion about it, others will take note.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2014


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