A CCO Job Function: Managing Talent

Garo Yepremian died this past week. For anyone who grew up watching National Football League (NFL) games in the late 1960s or 1970s; this was a name quite familiar to you even if you had trouble pronouncing it. Yepremian was a left-footed field goal kicker who went from the heights of glory such as once kicking six field goals in one game and ending the NFL’s longest game; the Miami Dolphins-Kansas City Chiefs 1971 playoff game which he won with a field goal in the second sudden death overtime. Unfortunately it is not these achievements that he is best known for. That rather ignominious distinction was when he had a field goal blocked in the 1973 Super Bowl against the Washington football team; then picked it up and tried to pass it only to have it slip from his hands into the arms of Mike Bass who ran it in for a touchdown. The score changed a one-sided game from 14-0 Dolphins to 14-7 and put their undefeated season on the line for the remainder of the game. Fortunately for posterity and Yepremian, the Dolphins held on to complete the NFL’s only undefeated season.

I thought about Yepremian, his gaffe and the fact he grew up in Cyprus playing soccer when I read a recent article in the Financial Times (FT), entitled “Game of talents: management lessons from top football coaches”, where Mike Forde and Simon Kuper wrote about how “football [soccer for you Yanks reading this blog] coaches grapple with egos, tantrums and rivalry. Business could learn a lot from them.” This is because talent management is a key component of any successful organization and none more so than on a soccer team where “Football managers are, above all, talent managers.” The article had some interesting insights for the Chief Compliance Officer (CCO) or compliance practitioner which I believe could be helpful when dealing with large egos found in any business organization.

1. Big talent usually comes with a big ego. Accept it. I grew up professionally in the private practices world of a law firm where big egos not only existed but also thrived and were perhaps even cultivated. This is not always true in the corporate world. The authors believe that “managing difficult people is the best test of a good manager.”
2. Look for big egos that have ‘gotten over themselves’. At some point we all grow up. In the business world, just as in sports, “some players underperform early in their careers because they are immature.” Maturity can lead to players “accept their limits and become coachable.”
3. Single out and praise those who make sacrifices for the organization. Reward those who might be willing to make a personal sacrifice. If you do, you behavior as a leader will be noticed and others in the business may well do the same.
4. The manager shouldn’t aspire to dominate the talent. In soccer “Talent wins matches…Successful managers accept this. They don’t try to emphasise their leadership by dominating talent.” As a CCO, you should not only work to help the business folks succeed but let them take the glory if a big deal is closed.
5. Ask talent for advice – but only for advice. While it seems self-evident, it always bears repeating if you take someone’s advice to craft a solution, that person will then be personally invested in the success of that solution. The authors quoted David Brailsford, general manager of the Team Sky cycling team, for the following, “We all perform better if we have a degree of ownership of what we do.”
6. The manager’s job isn’t to motivate. “Great talent motivates itself.” The converse of this means that if you have top-notch sales talent, part of your job as a CCO or compliance practitioner is “not to demotivate them”. But more than simply not ‘demotivating’ your job should be to encourage “long-term commitment: sustained motivation over time.”
7. Talent needs to trust each other more than it needs to trust the manager. This directly relates to the culture you set. If the only way for employees to succeed is to steal and cheat from their co-workers, you will have a toxic environment. Think of this in the context of your Foreign Corrupt Practices Act (FCPA) investigation protocol; if your goal is to skin some employee to save the company, you will not have much credibility left with your other employees.
8. Improve the talent. Unfortunately, most managers spend most of their time managing incompetent employees. The authors believe this is a wasted opportunity as most top talent “have a gift for learning and a desire to improve. That desire often drives their career choices.” For a CCO this means you need to provide such opportunities to those on your compliance team. But think about taking this concept out into the workforce. What if you could offer a top sales person or executive a chance to not only learn something but also advance their career by a rotation through the compliance department or a signature project they could lead?
9. 99% per cent of recruitment is about who you don’t sign. Here the message is to use your background due diligence to make sure that that ‘someone’ is the right person in the right situation because “Introducing a weak or undisciplined player [employee] can damage the standards and culture.”
10. Accept that talent will eventually leave. “Few talented people are looking for a job for life.” Indeed in the compliance arena, since there are no trade secrets around anti-corruption compliance, the skills a compliance practitioner uses can be easily translated into another company. I often think about Jay Martin, the CCO of BakerHughes Inc. (BHI) in Houston. He is now on his third generation of compliance practitioners who work under him. While they are at BHI they have the chance to work under and for one of the top in-house compliance practitioners around and for a company that has a robust compliance program. They work very hard while they are at BHI but they get great experience, a great resume entry and a great reference from one of the top compliance practitioners around. If you are a CCO you might consider the BHI model.
11. Gauge the moment when talent reaches its peak. In the sports world, the only person who wins every time (eventually) is Father Time. While that may not be as true in the corporate world, burnout is true. I went through it in my 40s as a trial lawyer and many others do as well. If you are a CCO and see reduced enthusiasm or commitment in an employee this may be the reason. Would you consider a sabbatical for the employee? How about a plumb overseas role to rekindle the passion? As a leader, you need to recognize this issue and use your leadership skills to address the situation.

The authors note, “Talent management has been a business obsession at least since 1997, when the consultancy McKinsey identified a “war for talent.”” As a CCO you should certainly consider these issues in managing your compliance function. However I believe the concepts laid out by Forde and Kuper work for the broader corporate world as well. If you are going to use you influence throughout the organization, you should consider incorporating these techniques into your skill set.

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

On Compliance Leadership: From Edward VIII to LeBron James

On this day in 1936 King Edward VIII became the first English monarch to voluntarily abdicate the throne. He chose to abdicate after the British government, public and the Church of England condemned his decision to marry the American divorcée Wallis Warfield Simpson. On the evening of December 11, he gave a radio address in which he explained, “I have found it impossible to carry on the heavy burden of responsibility and to discharge the duties of king, as I would wish to do, without the help and support of the woman I love.” Despite these protestations of love requiring his abdication, recent scholarship has suggested the King was forced out because of his sympathy to Hitler’s Germany. Indeed I recently saw a documentary, which went so far as to say that the King had agreed to re-assume the monarch’s throne if Germany had successfully invaded England. Whatever the reason or reasons, on December 12, 1936 his younger brother, the Duke of York, was proclaimed King George VI. England was certainly better off for it.

I thought about this excellent example of extremely poor leadership and what a Chief Compliance Officer (CCO) or compliance practitioner might be able to learn from it in the context of a couple of articles I recently came across in the Financial Times (FT). The first was by Andrew Hill in his ‘On Management’ column and was entitled “The dangers of a rising C-level for the business environment”. While the focus of the article was on chief executives, I found some of Hill insights also applicable to a CCO. Hill expressed concern about how chief executives embody “the fallacy of infallibility.” He decried that “The corporate world is similarly deluded in thinking that individual chief executives are a wonder drug that can be injected into ailing businesses. It is better to think of companies as systems. They may not work at all without some sort of hierarchy. But they work much better if managers and leaders recognise that they are merely a single, if important, component and that effective procedures and clear designation of individuals’ roles and responsibilities help the whole work smoothly.”

He cited to the example of one un-named chief executive who “said he had just two ways to influence the company: by setting the tone and culture and by “building the machine”.” I would translate this into process. Hill recognized that “Reliance on mechanical process alone is clearly dangerous. It could “induce mindlessness.” Rigorous procedures and training should instead free innovators to take the necessary risks and leaders to react in the right way to inevitable challenges.”

This means that training employees and giving them the tools to succeed should be a more important skill than simply following orders. If you train your business team in the basics of compliance and then provide the right support to them, it can help bake compliance into the DNA of a company. Simply put a top-down compliance program dictated from the corporate office in the US or UK will not be as effective as a CCO or compliance practitioner getting out into the field and getting the business team to view themselves as compliance colleagues and assume responsibility for doing compliance in everyday transactions.

The second article was by psychologist Naomi Shragai and was entitled “Bloated and shrunken egos both prove bad for business”. Shragai began her article with the following observation, “We are rarely the best judge of our own skills and achievements. Even with the best intentions, we tend to overrate or underrate our abilities. Deluding ourselves that we are better than we are boosts our confidence and helps us to recover from setbacks. Identifying faults in others, the company or circumstances is easier on the ego than believing any deficiency lies within. The problem with this attitude is that it is rooted in a misguided belief that there is nothing to learn or correct.” She also described the contradictory when she wrote, “At the opposite end of the continuum are people who underplay their abilities and tend to see the fault in themselves rather than in others. They might overcompensate for what they perceive as deficiencies in themselves by working hard, but, stuck in a cycle of negativity, they generally fail to take responsibility for their own development.”

Shragai suggests dealing with the former is important because in the long run “their behaviour needs to be managed early before it becomes self-reinforcing and harms the business…Let him or her know that you are not judging the person but the work.” For the latter behavior, she suggests, “The underconfident need to take more responsibility for listening to what others are saying by consciously tuning into reality rather than slipping into negative thoughts…Help them to recognise their skills by presenting them with concrete evidence of their accomplishments.”

From these two articles, I synthesized the importance of the process of compliance. The more that you can make compliance about process, the more you can take out the egos, the over-confident and under-confident out of the equation. But it is much more than a process, as it requires training and providing tools to the employee base and those employees on the front lines in high risk countries, areas, products and services so that they can deal with the situations which they might confront.

As a CCO or compliance practitioner, that means you have to get out of the corporate headquarters, put boots on the ground and learn what your business team’s challenges might be going forward. It also means to instruct them specifically on how to deal with situations where they may be faced with requests to pay bribes and the difference between bribes and extortion. If an employee is faced with a danger to his or her health, safety or liberty it is encumbent on you not only explain the difference but also absolutely support them to remedy or rectify the situation. As Hill said in his article, “building the machine” is a key way to influence a company. But once you build that machine, you have to support it and keep it running.

So today I would ask you to reflect on what the abdication of Edward VIII meant for the UK and even up until today with the current monarch, Queen Elizabeth II. You might even consider Prince William and Princess Kate hanging out with LeBron James.

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

Semper Fi and Compliance-Leadership Lessons from the Marines

Ever wonder where the US Marine Corp got its nickname of ‘hellhounds’? It came courtesy of the Imperial Germany Army from a battle that took place in the month of June 1918, the Battle of Belleau Wood. According to the Battle’s entry in Wikipedia, the Marines forces marched 10K to reach a site where the German Army had broken through against the French Army. After arriving on the site and turning back the German advance, the Marines were repeatedly urged to turn back by retreating French forces, Marine Captain Lloyd W. Williams of the 2^nd Battalion, 5^th Marines, uttered the now-famous retort “Retreat? Hell, we just got here.” 

After the battle, the French renamed the wood “Bois de la Brigade de Marine” (“Wood of the Marine Brigade”) in honor of the Marines’ tenacity. The French government also later awarded the 4th Brigade the Croix de guerre. An official German report classified the Marines as “vigorous, self-confident, and remarkable marksmen…” General Pershing – Commander of the American Expeditionary Force – even said, “The deadliest weapon in the world is a Marine and his rifle!” Pershing also said “the Battle of Belleau Wood was for the U.S. the biggest battle since Appomattox and the most considerable engagement American troops had ever had with a foreign enemy.” But it was the Germans who gave the Marine Corp its most lasting moniker, when the called them ‘the dogs from hell.’ Tribute indeed.

I thought about this tribute to the Marine Corp when I recently read an article in the Corner Office section of the New York Times (NYT), entitled “Leading By Putting Your Followers First”, by Adam Bryant. In this article, he profiled Don Knauss, the Chief Executive Officer (CEO) of Clorox Company. Knauss joined the Marine Corp after college and this experience gave him some valuable leadership lessons that Bryant detailed in his article. One of the things that influenced Knauss’ philosophy on leadership was the Marine Corp process of thinking through an issue. Bryant wrote, “I learned in the Marine Corps that I really liked strategy. Every operation in the military is based on a five-paragraph order, and the acronym is Smeac — situation, mission, execution, administration and communication. It’s a very logical flow.”

Another key leadership lesson is defined by the age-old acronym KISS or Keep it simple, sir. Bryant wrote that Knauss said, “how are you going to focus the organization? And it had better be simple, and it probably should not be more than three things. You’ve got to communicate it about 100 times and align your incentive structure to it. It’s about distilling the complex to the simple, and I’ve seen leaders fail because they do the reverse, by trying to make things into some intellectual exercise. Whatever business you’re in, there are fundamentals, just like blocking and tackling in football. It always comes back to the fundamentals. You cannot let yourself get bored with the fundamentals.”

But more than simply communicating something about 100 times to get your message across, Knauss believes that you have to make sure that people believe that you care about them. That is certainly something a compliance practitioner needs to take to heart. Knauss reflected, “it’s all about your people. If you’re going to engage the best and the brightest and retain them, they’d better think that you care more about them than you care about yourself. They’re not about making you look good. You’re about making them successful. If you really believe that and act on that, it gains you credibility and trust. You can run an organization based on fear for a short time. But trust is a much more powerful, long-term and sustainable way to drive an organization.”

Knauss had some interesting insights relating to how he evaluates potential hires that I think makes a lot of sense for the compliance professional to consider.

1. Passion – Knauss looks for energy and considers whether the person will have an impact on the business.
2. Smarts – Can the candidate think analytically, creatively and strategically?
3. Develop others – Is there any pattern in the person’s career that shows they can develop people or put inversely, did people move up through an organization because they were mentored by this person?
4. Communication skills – Knauss considers if he can imagine this person on a stage, inspiring a large group? He also assesses whether the candidate has an easy, informal manner to conversely test if they are too formal and too focused on hierarchy, as Knauss believes formality and rigidity do not work.
5. Use of power v. use of authority – Here Knauss believes “it is much more powerful to use authority than power. One of the things I’ve learned is that as you move up in an organization, you’re given more power. The less you use the power you’ve been given, the more authority people give you, because they think: “You know what? This guy’s O.K.” Persuading people to do things – come along with me because we’re going in the right direction – is much more powerful over time.”
6. Values – Knauss said that the final thing he tries to evaluate is the values of a candidate. He considers that it is important that they are honest and will tell the truth. Moreover, “do they also stand up for what they think is right in the company? It starts with integrity, which is really the grease of commerce. You get things done much more quickly when people trust you.”

However, I found one of the most important lessons that Knauss intoned was about how a leader should treat people. He told the story about how he joined a group of Marines who had been in the field for several weeks and had been eating C-rations. When Knauss met them, they were having their first hot meal since going into the field. Knauss related, “I had been up since 5 in the morning, and I was pretty hungry. I started walking over to get in front of the line, and this gunnery sergeant grabbed my shoulder and turned me around. He said: “Lieutenant, in the field the men always eat first. You can have some if there’s any left.” I said, “O.K., I get it.” That was the whole Marine Corps approach – it’s all about your people; it’s not about you. And if you’re going to lead these people, you’d better demonstrate that you care more about them than you care about yourself. I’ve never forgotten that, and that shaped my whole approach to leadership from then on.”

That final lesson is the most important one for any compliance practitioner. Your gold-plated written compliance program is only as strong as the people you have in your company. If you can demonstrate, and lead in compliance, by showing your fellow company employees that you are there to assist them but you will also go the extra mile to make them understand you care about them, you will get much more out of them at the end of the day.

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If you are interested in learning about mergers and acquisitions under the FCPA I am involved in to upcoming events designed to give you the most up-to-date advice on this area of compliance. Both events are sponsored by The Network. The first event is a webinar entitled appropriately enough, “Mergers and Acquisitions Under the FCPA” and is scheduled for  Tuesday, June 17th, 2014 TIME: 2:00 pm EDT. For registration and additional information click here. On Tuesday, June 24th the always popular Tom Fox/Stephen Martin roadshow returns to Denver where I will speak live on Merger and Acquisitions Under the FCPA and Stephen will talk about risk assessments under the FCPA. For information on the Denver event, click here. 

 

 

 

I am putting on a four part podcast series on the World Cup, detailing issues of bribery and corruption, together with an ongoing discussion of Team USA and this year’s tournament. I am joined by Mike Brown, the Managing Director of Infortal. You can check out Part I by clicking here of the series where we discuss bribery of referees in the lead up to the 2010 World Cup held in South Africa and FIFA’s response. Mike and I then review Team USA and it’s draw in Group g-the Group of Death. I hope that you will check out this series and enjoy it as much as Mike and I enjoy recording the episodes. Also remember, my podcast, the FCPA Compliance and Ethics Report is available for download at no charge on iTunes so you can listen to Part I on your commute to work. So sign up for the podcast from WordPress or iTunes and enjoy our series.

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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

 

 

 

 

Compliance Leadership Lessons from Captain Kirk

As readers of this blog know, I am an über Star Trek maven. Last week, in Episode 41 of  my podcast, the FCPA Compliance and Ethics Report,  I visited with John Champion, one of the co-hosts of the Mission Log podcast. Mission Log will eventually review all of the Star Trek television episodes and movie franchise entries. John and his co-host Ken Ray began their journey summer of 2012 and have managed to get through all 79 episodes of the original Star Trek television series. They will next turn to the Star Trek movies, the animated television series, then to Star Trek – The Next Generation and on down the line of the world built by Gene Roddenberry.

I met John at the NMX Annual Conference earlier this year. I heard him talking about his podcast and checked it out. I also asked him if I could interview him for my podcast, specifically on the leadership lessons that a compliance practitioner might draw from the original captain of the Enterprise, James T. Kirk. John graciously took time out of busy schedule to visit with me on leadership, Star Trek and his podcast, Mission Log.

Champion views the leadership style of Captain Kirk as one that greatly depends on the inputs from the group that surrounds him; specifically Lt. Commander Spock and the ship’s physician, Dr. Leonard McCoy (Bones). In other words, his senior management team. More insightfully, Champion noted that it is the interplay of these three characters, Kirk, Spock and McCoy that not only makes the television series work so well but it also informs what he termed the “leadership psyche” of ethos, pathos and logos.

In the Greek world, these three were believed to be the key to successful leadership. Ethos is the Greek word for ‘character’. Through ethos, a leader stands as an authority figure, through credibility, competence and/or special expertise. Pathos is the Greek word for both ‘suffering’ and ‘experience’. It is generally recognized as the more compassionate side of humanity. Logos generally refers to the more rational side of humans. The best definition I have found for logos is on the site, PathosEthosLogos.com, which says that “Logos is the Greek word for “word,” however the true definition goes beyond that, and can be most closely described as that by which the inward thought is expressed and the inward thought itself”.

In the original Star Trek all three of these traits are identified in one character. Kirk, the ship’s captain, is the authoritarian figure. Spock, the half-human, half-Vulcan subscribes to the Vulcan ideology of suppressing one’s emotions in favor of logic. Finally, Bones is the romantic of the three and clearly speaks for the Greek concept of pathos. Champion’s dissection of Kirk’s leadership is that he takes all three of these concepts and uses them in his analysis. While clearly, at the end of the day, the decisions are the final responsibility of Kirk, he does actively seek input from his trusted advisors before coming to his final choice.

For the compliance practitioner, this means that you should seek a wide variety of inputs for your decision-making calculus. The Machiavellian trait of seeking trusted advise from experienced advisors, (Subject Matter Experts – SMEs) is certainly in play here. But by incorporating these three very different concepts into the way you might think through an issue can help you to evaluate a greater range of considerations. Monitoring, auditing and similar oversight techniques can bring you the logical examinations through data. But data is, in the final analysis, a product of human actions so the data must be read with some measure of humanity or human character. Values are not numbers but how we assign actions to that raw data? Finally, the ethos must be taken into account. Obviously there must be an ethical component to any decision made, but ethos also speaks to the character of the decision. Was the decision made using all the facts that were, or should have been, available to the decision-maker?

I thought about Champion’s remarks when I read the New York Times (NYT) Corner Office column by Adam Bryant, entitled “When Ideas Collide, Don’t Duck”. In this article, Bryant reported on his interview with Jeff Lawson, Chief Executive Officer (CEO) of Twillio, a cloud communications company. Lawson spoke about all three Greek leadership concepts in both his education in being a company head. From the ethos perspective, he spoke about his grandfather who built and sold a hardware company in Detroit. Then in his 70s, his grandfather took a job as a manufacturer’s representative, selling paint accessories to hardware stores that had previously been his competitors. His grandfather did this for another 20 years and when he died, Lawson said, “The Owner of every hardware store in Detroit came to the funeral. It was amazing.”

Lawson had another insight, which related to pathos and it revolved around feedback. He said, “This is especially important with millennial workers, who really want feedback. They want to always be learning, always be growing, and they’re looking for that constant feedback. It’s not that they’re looking for constant praise, but rather they want to keep score. They want to know how they’re doing.  Part of it is the short cycle of Internet feedback, and people who grew up with the Internet just expect quick feedback on things. That’s just part of the changing ethos, especially with younger workers. If you get into the habit of regular feedback, it’s not confrontational; it’s just the ebb and flow of conversation and a constant tweaking of how you work with somebody.”

Lawson incorporates the logos concept into his leadership set as well. He does this in the context of empowering employees to come up with new ideas but requires these employees to validate them to move forward. He said, “A lot of our values are about empowering employees. “Draw the owl” is a favorite. It’s based on the Internet meme of how to draw an owl. It says: “Step 1, draw some circles. Step 2, draw the rest of the owl.” That’s what it takes to be an entrepreneur — you have to put aside all the reasons you think you can’t do something or figure it out. Our job is to come in every day and take a vague problem that we don’t know how to solve and figure out the solution.”

Does art imitate life or does life imitate art? I am never too sure. But from my chat with John Champion, it is clear that even such a cultural marvel as Captain James T. Kirk can provide leadership lessons for the compliance practitioner.

If you have not yet done so, I hope you will go over and check out my podcasts at the FCPA Compliance and Ethics Report. I am up to Episode 41 and should have a couple more up this week. 

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

Lessons from a Soccer Manager for the Compliance Practitioner

Compliance leadership can take many forms and inspiration can come from many different sources. I was reminded of this when I read an article in this past weekend’s Financial Times (FT), entitled “How I coach Ronaldo and other secrets”, by Simon Kuper who wrote the piece based upon his interview of Real Madrid manager, Carlo Ancelotti.

Ancelotti grew up professionally playing in Italy’s Seria A, the top league in that soccer-crazed country. So he brings a player perspective to his job. He also rose in the soccer coaching ranks, with stops at Juventus and AC Milan in Italy; then Chelsea in England; followed by Paris Saint-Germain in France before taking over the reins at Real Madrid in Spain. So he has been both a practitioner and an executive. I found some of his thoughts on coaching very insightful for the compliance practitioner.

Coaching a Multi-National Team – Translating Your Compliance Program into Native Languages

While at AC Milan, Ancelotti coached a wide number of different nationalities so being able to communicate with them was critical. This was important when coaching in Italy but Ancelotti found it much more difficult when he moved to England to take over as the manager for Chelsea. He said the hardest part of the communication piece was how “to show emotion”. As any compliance practitioner for an international business concern recognizes, communicating in a multiplicity of languages is a paramount skill.

This is an area that is receiving increasing attention from the Department of Justice (DOJ) as a component of a best practices compliance program. In the FCPA Guidance, under the Ten Hallmarks of an Effective Compliance Program, it intones that a company’s Code of Conduct and it’s compliance policies need to be clear and concise. However, equally noted is that the Guidance makes clear that if a company has a large employee base that is not fluent in English such documents need to be translated into the native language of those employees.

Trusting Your Players – Getting Buy-In For Your Compliance Program

While managing Chelsea, before the 2010 FC Cup final against Portsmouth, “Ancelotti did something unusual: after naming the starting 11, he asked them to decide the match strategy themselves.” He recalls: “Everyone said one thing. For example, [goalkeeper Petr] Cech said, ‘You have to control the space behind, to avoid the counter-attack.’ That season we played 60 games, and 60 times I made the strategy. So I think the players understood very well what they had to do.” When asked why he would try something so risky before such an important match, Ancelotti responded, “I was sure the players followed the strategy, because they made the strategy. Sometimes I make the strategy, but you don’t know if the players really understand.” His tactic worked and Chelsea beat Portsmouth 1-0 to complete the rare double of winning the English Premier League and the FA Cup.

What Ancelotti had hit upon was engaging his players. You should view every interaction as an opportunity to tap into the expertise of your workforce. This requires you to let employees say what they think. One of the first (and most insistent) questions you will face as a compliance practitioner is explaining how and why the Foreign Corrupt Practices Act (FCPA) applies to a country and culture far from the United States. Another related question is often along the lines of the endemic corruption in a country and how the business unit personnel cannot do business any other way. Let your co-workers express these thought and sentiments and then explain why the law(s) applies and how they can do business going forward. The business unit will usually have a solution to these problems and if you can get them to engage with you, it may well be a solution for you and the company. My experience is that they will generally have the correct response for you, even if they do not understand the nuances of the FCPA, UK Bribery Act or other anti-corruption law. But if you can have the employees understand that it is there program, you will have greater buy-in and greater participation in your compliance regime.

Managing from the Ground Up – Thoughts on Building a Compliance Program

After his stint at Chelsea, Ancelotti moved on to Paris Saint-Germain in France. Here he found a different set of challenges. The first was dedication to the program and lack of professionalism. As Ancelotti explained, “The problem of the English player – sometimes it’s difficult for them to understand that they don’t have to work 100 per cent in training. There are some training sessions where it’s important not to work 100 per cent. The French don’t understand why they have to work 100 per cent every day.” This attitude was acerbated by factionalism; the team was made up of ethnic factions. Ancelotti said, “We had the South Americans, the French, the Italians,” and “The relationship is not easy. The South Americans like to play with each other. The Italians the same. The players were not used to having a winning mentality.” Simply put, he had to change the attitude of the players.

How can you begin this process in a compliance regime? Writing in the Harvard Business Review (HBR) authors Linda Hill and Kent Linebeck, in an article entitled “Are You A Good Boss or a Great One”, said that leadership had three imperatives, which are to (1) Manage Yourself; (2) Manage Your Network; and (3) Manage Your Team. These three imperatives provide a good framework for the compliance practitioner.

Most employees ask the question “Can I trust this person?” Leadership results, in large part, by the answer to this question. Trust has two components; the first is that the leader has confidence in his or her own competence; and the second is that employees have trust in the manager’s character. This means that your motives are good and that you want people to do well. If these characteristics are present a manager should be able to influence others.

Next building key relationships throughout an organization leads to the road for success. This means nurturing a broad network of company employees who can influence specific areas and the departments within a company. As scarce resources must be reckoned with on any project, the person who can show the interdependence of seemingly disparate groups, which may have conflicting goals and priorities, is the manager who achieves the most. This relationship building can be a key way to influence others within an organization over which a manager does not have direct control.

Lastly, managing a team is a different dynamic than managing one-on-one. If a manager can influence a team, they have a greater chance of success as employees tend to be more creative and productive when working in groups. Accountability to other team members and a genuine conviction that they are all in it together can lead to a group coalescing into a team. The culture of any team is important: values, standards and norms guide employees in what is expected of them. Attention must be paid to all team members and recognition for individual efforts within the team can bring greater effectiveness as well.

To be a great compliance leader, the compliance professional must use all of these techniques. To achieve many compliance goals within a company requires a manager to exert a great amount of influence. The techniques set out by the authors provide direct tools for the compliance professional to utilize in this task. Managing employees within any compliance department is the first step. A compliance professional must reach out across an organization to all groups and departments to develop relationships, which can be used in furthering a company’s compliance goals. A compelling team creates the foundation of this strong network and a strong network will allow your compliance team a path to achieve its goals within the company. But knowing where you are going is only half of the journey. The authors end with the admonition that “you need to know at all times where you are on the journey and what you must do to make progress.”

Obviously Ancelotti has been successful at many different stops in his career. Some of the tips that Kuper wrote about in this article can be useful for the compliance practitioner dealing with a diverse multi-national employee base.

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

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

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.

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, 2013

Why Should the Boss Listen to You: Compliance Professional as Trusted Advisor

July 2, 2012, was the 150^th anniversary of the Morrill Act. This piece of Congressional legislation established land grant colleges throughout the United States and paved the way for the establishment of colleges in each state to teach the practical sciences of agriculture and mechanical arts, among other things. If you went to a college or university with the designation “State” or “A&M” attached to it, you can direct your thanks to the 37^th Congress for enacting legislation which provided both land grants and financial assistance. That is why such institutions of higher learning are termed “land grant colleges”. It was a clear case of Congress listening to the needs and desires of the American people.

I often write about the art of listening as one of the skills critical to being a successful business leader. However, if you are a compliance practitioner you need to have developed the necessary skills so that the senior management in your company will listen to you. This subject was touched on in the March/April issue of the SCCE Magazine, Compliance and Ethics Professional, in an article entitled “Does your boss listen to you?” by Meric Craig Bloch. In his article, Bloch notes that “Compliance professionals are business advisors”; as such they can never be effective if senior management does not listen to them. Bloch advises that the key is to become a “trusted advisor” to capture the attention of key decision makers at your company.

Bloch understands that the need to “be relevant is a constant challenge for any business advisor.” He cites to management expert Jim Lukaszewski and his book “<em>Why Should the Boss Listen to You” for a seven point approach to becoming a trusted advisor to senior management. These seven disciplines are:

1. Be trustworthy: Trust is the first discipline and the foundation for all business relationships between an advisor and business leadership.
2. Become a verbal visionary: Generally a leader’s greatest skill is to articulate his or her vision in a way that is compelling and motivates employees; in other words, good verbal skills. This means that any successful leader’s trusted advisors need these skills as well.
3. Develop a management perspective: A trusted advisor cannot simply talk about their staff functions. A trusted advisor must be able to integrate his or her message into management’s goals and objectives.
4. Think strategically: As a leader’s job is almost always about tomorrow, a leader must have a strategic vision. This means that a trusted advisor must not only think strategically within your discipline but you must also integrate your function into the leader’s strategic plan.
5. Be a window to tomorrow: What are the patterns of your business or your professional discipline? The more that you can study and understand them, the more helpful information that you can put in front of your company’s leadership.
6. Advise constructively: You should start with where the leadership in your company has been and move your advice into where they want to go.
7. Show the boss how to use advice: This means more than having your boss accept your advice. You need to develop the skills to teach your leadership how to use your advice as well.

Bloch concludes by correctly recognizing that “every compliance issue, is ultimately, a business issue.” I often tell executives that compliance is another form of risk and as such you can measure, evaluate and then manage it. If the risk becomes too great to manage, that may create an unacceptable level of risk which your company will not tolerate. As a compliance practitioner, one of your key roles is to reduce the number and level of risks which your company cannot or will not tolerate. This is a major mechanism by which you can demonstrate the value of compliance within the organization and ensure that your contribution is relevant.

But it can only occur if your boss will listen to you.

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, 2012

Don’t Fold ‘Em: Making the Case for Ethical Leadership

In an article published in the June issue of ACC Docket, entitled “Playing the Cards You’re Dealt”, James Nortz raised the interesting issue of the lack of company leadership to “create an ethical vision, the moral courage to pursue that vision and the ability to effectively communicate the vision to others.” I think that most of us will recognize ‘Tone at the Top’ as a key component of any successful compliance program. It is certainly recognized by the Department of Justice (DOJ) in its best practices for a Foreign Corrupt Practices Act (FCPA) Compliance Program. Nortz propounds that a “root cause” for many compliance failures is that management is not fully committed to a strong ethical culture. He noted that according to the “Ethics Resource Center’s 2009 National Business Ethics Survey, only 18 percent of US corporations have a strong ethical culture.”

He posed the question of what can you do as a Law or Compliance Department member to facilitate the creation, implementation and sustainment of a strong ethical culture, where such initiative is not found in the company leadership, and play with the weak compliance hand you may have been initially dealt. He laid out four steps to think through this process.

1. Engage in the research and study necessary to develop a clear and realistic vision of what “good” or, better yet, “great” would look like for your firm. This vision can be developed by tapping into the vast body of literature on compliance and ethics. An additional resource is to reach out to other legal/compliance professionals who are usually very willing to share the experiences of their companies.
2. Plan your internal marketing efforts carefully. My colleague Howard Sklar often talks about the internal sales efforts that a compliance officer must make to obtain additional funding for compliance programs. Here your challenge may be greater as you are marketing a new concept or program. According to Nortz, “you must identify, and be able to articulate, concrete benefits your company will realize as a consequence of investing time and money in pursuing your vision.” This should translate into the following business concepts: enhancement of your company’s reputation, a lowering of conduct which may violate anti-corruption proscriptions, improvement of workforce engagement and productivity, lowering of overall enterprise risks, all of which will lead to a measurable return to the bottom line.
3. Develop a strong game plan. Nortz suggests using three questions based on Machiavelli’s “The Prince”. They are: (a) Have I done all I can to secure my position and the strength and stability of my organization? By this he means that “if you have no power or influence over others, you have no chance of affecting organizational change. (b) Have I thought creatively and imaginatively about my organization’s role in society and its relationship to its stakeholders? This requires that your vision for a compliance and ethics program must be attuned to your company’s overall mission. (c) Should I play the lion or the fox? Nortz believes that this necessitates fluidity in your approach, strong as lion at times and wily like my four-legged brethren when need be.
4. Think long term. This means you must consider something beyond, weeks, months or the next quarter. The transformation of a corporate culture takes time. This may be truer if this change comes from the legal/compliance department rather than the Chief Executive Officer (CEO). Even if you can obtain CEO buy-in and leadership, you may likely be the driving force, do not be discouraged as no one among us has attached perfection in this area.

Nortz ends by noting that taking on the challenge of helping your leaders develop the skills necessary to build and sustain a strong ethical culture is not an easy task. He believes that such “work requires unrelenting determination, extraordinary shrewdness and guts.” However, the results can be well worth it. He has laid out several steps that you can incorporate into your overall compliance strategy, whether or not you are seeking to implement an initial compliance program or enhance an existing program. I would recommend that you consider some or all of the steps that he has proposed and to “play the cards you’ve been dealt as best you can.”

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, 2011

Fostering Compliance Across Your Company

In the July-August issue of the Harvard Business Review, in an article entitled “Are You a Collaborative Leader”, authors Herminia Ibarra and Morten Hansen discuss how great Chief Executive Officers (CEOs) keep their teams connected. The authors’ basic thesis is that the hyper-connected business world of today demands a leadership style which harnesses the power of connections. I found that the article had some excellent suggestions for the compliance practitioner regarding communication with employees outside the Compliance Department and indeed throughout the world. The authors had five general points which I believe, if incorporated into your overall compliance program, will strengthen it by increasing communication and cooperation with the compliance department.

I. Play Global Connector

My colleague, Mary Jones, often talks about her experiences in going out across the globe to perform training. This experience also has the great benefit of allowing her to meet the business development people in the field, to put a name with a face and talk privately with persons away from the dreaded ‘home office’. The authors state this type of person as a “connector” who gets out in the field makes themself personally known. Connectors want to find out what people think and why they think that way. Sitting in the home office and waiting for the phone to ring is not always the best way to determine this. You have to get out in the field to gain credibility but to also be known as the person in the compliance department that someone in the Far East (or Middle East or Central Asia-name your location) can call anytime with an issue.

II. Engage People at the Periphery

As much as companies try to make all employees conform to one compliance program across the world, it is simply not possible to do so. This does not mean that bribery and corruption is acceptable in some places but not in the US (or the dreaded ‘it’s just the way business is done here’ syndrome). Customs and relations are different across the globe. There needs to be some cultural sensitivity. As a compliance officer you can be firm about upholding your overall compliance goals but do it in a much more sensitive manner than simply saying that is the policy and you had better follow it. I once heard a Chief Compliance Officer (CCO) answer a question about how he explained to an Vietnamese employee about how corruption in his country hurt everyone and the company’s compliance policy was one way in which the employee could ‘move the ball forward’ regarding bribery and corruption.

III. Leadership at the Top

The authors define this as “depoliticizing senior management so that executives are rewarded for collaborating rather promoting their individual agenda.” The clear reason this is important is that in the area of compliance, as with all other areas, tone at the top is critical. If compliance is seen as valued at the top, it will cascade down. Every compliance officer knows that without the support of top management, a compliance program is doomed to failure. This also means that the goals of compliance need to be incorporated into overall leadership goals. If goals are simply performance based, employees will understand that is what the company values. In other words if senior management only talks the compliance talk but grades everyone on quarterly perform, guess what employees will understand is important.

IV. Show a Strong Hand

This translates into allowing employees across the organization to make first-line compliance decisions, after appropriate training. While a company can centralize all compliance functions in the US home office (remember the dreaded‘home office’ scenario); if the compliance department can get out into the field and train, it will make the organization more agile in compliance. Compliance leadership should assign clear rights and responsibilities to employee sponsors or advocates but allow them to do their jobs without watching over them or second guessing every decision. The point of decentralizing is to do just that but do not require that every decision be committed to death or agonized over. There is plenty of time for that with much bigger compliance decisions.

V. Loosening Control without Loosing Control

Collaboration does not necessarily mean consensus. The power of this model is to allow a wide range of views across different silos within the company. As with point IV above, you can make a decision when required, but take the company’s pulse. Interconnectivity is certainly a by-word with all international Fortune 500 companies now so take advantage of all of the resources. Even if you cannot get out on the road or head over to China when a question or issue arises in China, you can tap into those resources which you have cultivated through connectivity.

Even after such a decision is made, be sure to follow-up with your connected resources. Now is the time to get out of the home office to visit your foreign in-country connections. This demonstrates a clear commitment to the persons involved and also demonstrates to all the employees around them that compliance views them as resources which the compliance department will tap into.

The clear thesis of this article is to connect with employees outside of your Compliance Department to assist you. If you do so, these connections will be some of your strongest advocates to do business the right way in your company.

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, 2011

Being a Great (Compliance) Leader

In the most recent issue of the Harvard Business Review, writers Linda Hill and Kent Lineback posed the question, “Are You a Good Boss – Or a Great One?” In this article they explore what they believe to be some of the imperatives of going from a good boss to a great boss. Recognizing that the focus of the article is to help people grow as leaders within their businesses; we believe that their ideas have application in the compliance arena. We will therefore review the article with a emphasis on helping employees to become great compliance leaders – whether you measure compliance through the US Foreign Corrupt Practices Act (FCPA); UK Bribery Act or any other standard.

Hill and Lineback begin with the thesis that most managers underestimate the transformational nature of the challenge of their roles as company leaders. To be a great leader a person must be dynamic and not complacent. If a leader stops growing and improving they run the risk of becoming a terrible boss. The authors believe that most managers stop working on themselves at some point in their career. Many managers are afraid of failure and this leads to a fear of change. Others do not receive proper training or support from their companies. Whatever the cause, the authors believe that most managers stop making progress because “they simply don’t know how to.” Even when there is adequate company support for change, it is sometimes difficult to know what is required to become an effective manager.

To aid such persons, the authors have developed what they term the “3 imperatives” to help managers on their “journey to becoming great bosses.” These imperatives are (1) Manage Yourself; (2) Manage Your Network; and (3) Manage Your Team. We will review  these and reference how they apply to being a great compliance leader.

Manage Yourself

The authors believe that most employees ask “Can I trust this person?” Leadership results, in large part, by the answer to this question. The authors state that trust has two components; the first is that the leader has confidence in his or her own competence; and the second is that employees have trust in the manager’s character. This means that your motives are good and that you want people to do well. If these characteristics are present a manager should be able to influence others.

Manage Your Network

The authors believe that building key relationships throughout an organization leads to the road for success. This means nurturing a broad network of company employees who can influence specific areas and the departments within a company. As scarce resources must be reckoned with on any project, the person who can show the interdependence of seemingly disparate groups, which may have conflicting goals and priorities, is the manager who achieves the most. This relationship building can be a key way to influence others within an organization over which a manager does not have direct control.

Manage Your Team

The authors believe that managing a team is a different dynamic than managing one-on-one. If a manager can influence a team, they have a greater chance of success as employees tend to be more creative and productive when working in groups. Accountability to other team members and a genuine convict that they are all in it together can lead to a group coalescing into a team. The culture of any team is important: values, standards and norms guide employees in what is expected of them. Attention must be paid to all team members and recognition for individual efforts within the team can bring greater effectiveness as well.

To be a great compliance leader, the compliance professional must use all of these techniques. To achieve many compliance goals within a company requires a manager to exert a great amount of influence. The techniques set out by the authors provide direct tools for the compliance professional to utilize in this task. Managing employees within any compliance department is the first step. A compliance professional must reach out across an organization to all groups and departments to develop relationships which can be used in furthering a company’s compliance goals. The foundation of this strong network is created by a compelling team. A strong network will allow your compliance team a path to achieve its goals within the company. But knowing where you are going is only half of the journey. The authors end with the admonition that “you need to know at all times where you are on the journey and what you must do to make progress.”

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, 2011