Wednesday, August 21, 2013

YOUR DREAM TEAM: Where Everyone is a Compliance Leader

"In looking for people to hire, you look for three qualities: integrity, intelligence, and energy. And if they don't have the first, the other two will kill you." ~ Warren Buffet

“The supreme quality for leadership is unquestionably integrity. Without it, no real success is possible, no matter whether it is on a section gang, a football field, in an army, or in an office.” ~Dwight D. Eisenhower

Who leads legal and regulatory compliance at your organization?

How many of your employees are in a compliance role?

Before you respond, consider this…every employee in my organization is in a compliance role...and is charged with being a compliance leader. We only hire compliance leaders to fill each open position throughout the organization. Sales. Operations. Human Resources. Accounting. Facilities Maintenance.

You may be wondering why an organization would engage in such a hair-brained staffing strategy. (You may also be wondering how much longer such an organization could remain in business.) But hearkening back to the words of Warren Buffet and President Eisenhower above, how else could you possibly select talent?

In today’s increasingly complex international regulatory topography, no function within your organization escapes the need to develop policies, processes and training that will address compliance requirements at all employee levels. A CEO cannot simply rely upon on an Internal Audit function, a Legal Department, or a Regulatory Compliance team to identify and mitigate all enterprise-wide risks.

Further, day-to-day compliance and risk management responsibility cannot fall solely upon the shoulders of department heads or supervisors. As leaders, each of you knows that there are far more events occurring for which you are unaware than those that do rise to your attention. Each of our employees—from the most senior to the newly-hired—must understand his/her vital role in preventing, identifying, reporting, and resolving the compliance issues that affect his/her respective role and department.

We must hire individuals that bring the added skill of compliance awareness. I want:

• a talented facilities maintenance employee who also appreciates the impact the EPA and OSHA have at our organization;
• a certified public accountant who also appreciates the impact that the SEC and PCAOB can have;
• a customer-focused call center agent who also appreciates the impact that the FTC and FCC can have; and so forth.

Myself, I’d rather have thousands of sets of eyes mitigating risk globally than to rely only upon my own comparatively limited viewpoint. So, let me ask those questions a different way now…

Who doesn’t lead legal and regulatory compliance at your organization, and why not?

How many of your employees aren’t in a compliance role, and why not?