FCPA Compliance and Ethics Blog

July 28, 2015

How to Succeed In Compliance – The Compliance Retreat

How to Succeed in BusinessIn 1961, one of my favorite Broadway musical comedies appeared How to Succeed in Business Without Really Trying. It ran for over 1400 performances in its original Broadway run and was based on the 1952 book by Shepherd Mead, entitled “How to Succeed in Business Without Really Trying: The Dastard’s Guide to Fame and Fortune”. The book is a satire of an instructional manual and pokes fun at (then) contemporary office life in the United States in the guise of a self-help book. It details the rise of one J. Pierrepont Finch, from window washer to Chairman of the Board in only two weeks.

The play was later adapted into a movie in 1967. Robert Morse played the lead role in both the original theatrical run and the movie, with Matthew Broderick and Daniel Radcliff taking the role in 2000 era revivals. My favorite song from the movie is I Believe in You, which Finch sings to himself in front a Men’s Room mirror immediately before going to a big meeting. Most interestingly when Mead’s book was re-released in 1995, in connection with a revival of the play, the Library of Congress cataloged it as non-fiction under “business books”, with the subject headings “Success in business”, “Management”, and “Career development”.

I wondered how I could help corporate compliance departments better succeed in compliance? So inspired by Finch to help all corporate compliance departments, Chief Compliance Officers (CCOs) and compliance practitioners succeed, today I am announcing a new service offering: the Compliance Retreat. Why a strategic retreat? It is unlikely you can explore the wide range of issues that you might need to consider by simply performing a risk assessment and going forward. While a risk assessment is a key tool, it is only one tool. The Compliance Retreat will allow you to work through a wide range of compliance issues specific to your company, your risk profile, your industry and your culture. Taking time to discuss compliance issues large and small in a one day Compliance Retreat will allow you to think differently about your compliance program, all facilitated by one of the top Nuts and Bolts compliance practitioners around.

The role of facilitator is crucial for several reasons. First, and foremost, you should have a neutral party, one with no stake in the outcome. This means that you should not bring in your regular counsel or compliance advisors because they will have a vested interest in projects moving forward. Further, the facilitator needs to be well versed in not only the anti-corruption compliance field but also someone who has seen a wide variety of best practices in compliance in multiple businesses and industries. In the compliance field many practitioners want to know what other companies are doing and how they are facing unique challenges in many areas. Only an expert in the compliance arena can bring all of these skills to bear.

What should the Compliance Retreat look like? A visual representation would be the following:Compliance Retreat


It starts with a Facilitator prepared to discuss your compliance program; the current structure, risk assessments, audits and outstanding issues at this time. A Facilitator could then help lead a discussion based on wide compliance discipline knowledge for steps to consider in building your program. From there, you can move towards building out and enhancing your own compliance program. It would end with actions and steps that can be measured moving forward.

The Compliance Retreat is more than simply getting away for one day to discuss the specifics of your compliance program. Sarah Kessler, writing in an Inc.com article, entitled “How to Plan a Company Retreat”, listed some of the key principles of a strategic retreat that I have adapted for the Compliance Retreat. They include:

  • Collaborate. Make certain that all participants have the ability to collaborate.
  • Make discussion introvert-friendly. Ask the participants to write down answers to questions instead of blurting them out, and ask every person in the room to give their opinion in an organized manner.
  • Encourage people to express themselves. It is important that all opinions are heard and make certain that minority opinions have a way to be heard.
  • Combine team building with work. Compliance is always about teamwork so your compliance team should decide their next steps in the future, versus just experiencing a task together and deciding that the group can simply work well together.
  • Stay on topic. It is important to stay focused on compliance issues.
  • Diverge, converge. You should break up your group for more focused discussions then bring them back to the larger group for discussion.
  • Document your next steps. Assign a champion for each step that the compliance team has agreed on, making those steps as specific as possible. You should document who does what, when they will accomplish the task and how, at the end of the day, you will measure it.

Through my new service offering the FCPA Master Class Training I will be bringing the most current best practices on the nuts and bolts of FCPA compliance to a wide variety of compliance practitioners across the US. With the Compliance Retreat I will be able to offer the best practices to any compliance department or similar corporate function that wants to have a facilitated, focused retreat on its compliance program. Imagine you could focus for one day on your compliance program and be able to pick the brain of the one of the tops Nuts and Bolts compliance practitioners around. Now you have the chance. What will it cost to have such a service? You will have to contact me, via email at tfox@tfoxlaw.com, for that information but it will be a fixed fee service so you know what your cost is going in with no surprises of hourly rate or multiple lawyers and support personnel showing up on the invoice.

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, 2015

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