COMPLIANCE: A VALUE-ADDED SERVICE TO THE ORGANIZATION

“It’s a sign of troubled times when the concept of ‘pressure’ becomes an acceptable excuse for ethical shortcuts and moral shortcomings. Pressures are just temptations in disguise and it’s never been acceptable to give in to temptation.”  ~Michael Josephson

As a profession, we have worked diligently to shed the stereotype that long-plagued us, that of being a legalistic cost-center who impeded organizational growth. [While you may not have ever personally experienced the stereotype, let me assure you that many of us have received the sarcastic “oh, here comes Audit/Compliance…”]

Like me, many of you regularly engage in projects within your organizations to provide the compliance and ethics (C&E) perspective.  In some organizations, we are routinely invited to project planning sessions and kick-off meetings, remaining to consult with the project team until implementation. In other instances, we become aware of an in-process initiative that contains elements of regulatory risk and invite ourselves into the project. Either way, C&E professionals provide valuable subject matter expertise to ensure that the organization’s we represent are well-grounded in compliant activities.

That being said, I was reminded recently that our work is not over. A colleague had relayed to me a situation at her organization that continues to cause dismay to C&E professionals. During a stakeholder meeting to explore system integration and replacement options, my colleague put forth a variety of system security and operational suggestions to strengthen the information security and consumer compliance framework from inception. After dismissively alluding to costs associated with these suggestions more than a few times during the meeting, the project leader looked up at my colleague and replied, “Well, we may not be able to incorporate each of these items, but—you know—sometimes you just have to go along to get along…” Apparently, the project leader even slyly winked at my colleague as this was said.

I get a little choked up as I recount my colleague’s reply, as with a spine of steel she looked back (without a wink) across the table and said, “Well, no. This organization doesn’t knowingly build non-compliance into its new initiatives, so I wouldn’t sign off without the controls in place.” When the project leader published the next version of the system requirements, each of the compliance components had been incorporated as submitted, and had been risk scored accordingly.

We are going to be asked to participate in many initiatives over the course of our C&E careers. Certainly we will always seek the most cost-effective and internally-conducive methods to achieve compliant outcomes, because we believe in our organizations and wish to help them succeed in the marketplace.

But occasionally we are going to be asked to step beyond the fiduciary responsibility with which our Board has entrusted us, and which society expects of us. It is in those moments when our fidelity to doing the right thing will supplant simply bowing to doing the popular thing. It is in that moment of fortitude and loyalty to duty that we will have added true value to our organization…

DROP THE PRETENSE! (AND ACHIEVE THE OBJECTIVE)

"In dwelling, live close to the ground. In thinking, keep to the simple. In conflict, be fair and generous. In governing, don't try to control. In work, do what you enjoy..." ~Lao Tzu 


 "Authority is always built on service and sacrifice." ~James C. Hunter, The Servant  






"This project would move along much more quickly if everyone assigned to the project actually wanted to be on the team," remarked a client at the outset of our recent meeting. I prodded her for additional detail.


"For instance," she continued, "while most of us arrive for the project meetings on time and prepared to focus upon the agenda, we have a few members who straggle in, phones still attached to their ears, wearing undisguised disdain for being burdened with having to attend the meeting. We are all managers and supervisors in our various areas, but for some reason it appears that these few believe that their position should exempt them from having to work on the project. When drawn into the discussion by the Project Leader, these few individuals deflect commitments or delay sharing needed data from their areas of responsibility. Worse, they sometimes become downright abrasive when pressed by others who are relying upon those commitments or data."


As my colleague Robert Whipple discusses in "Wag More, Bark Less", a barking dog is simply warning possible encroachers to steer clear of his territory. But almost nothing could be less desirable in the workplace than an environment of feared territorial encroachment. In the ever-increasing competitiveness for consumers in our industry, as Leaders and Team Members we must become more effective collaborators at cross-training, supporting one another's efforts and ultimately delivering the best products and services to fulfill our members'/customers' needs.


As a contracted Project Team Facilitator, I cannot afford myself the luxury of brandishing my title and authority or shirking my responsibilities to the Project Team or to the Organization. An effective Project Team requires that ALL members of the team--regardless of organizational title or number of employees reporting to them--must come to the Project Team as equals in responsibility. The Organization forms a Project Team for a sole purpose: To Achieve the Objective.


Perhaps your Organization is merging with another Organization; launching a new technology platform; rolling out a new loan product. At the end of the Project, regardless of the detail of the metrics, success will ultimately be measured by: Did We Achieve the Objective?


How do you ensure that individual pretense, self-importance, and other personal blindspots do not reduce your Project Team's effectiveness?

1. Early in the project (best: at the kick-off meeting), communicate the shared expectation to all assigned Team Members that you are coming together as a Team of equals, chosen for the respective strengths and expertise that each individual brings to the Project Team.
2. If during the project life cycle certain individuals fail to fully engage or actively disassociate themselves from the shared responsibility to the Project Team, then politely but directly remind those individuals of the path between their participation/contribution and the successful achievement of the Project Objective.
3. Follow up as necessary with offline one-on-one dialogue to uncover any additional reasons that the recalcitrant individual may have for failing to support his own shared responsbility to the Project Team.
4. When personal responsibility and inherent professionalism fail to spur that individual to shoulder his responsibility to effectively achieve the Project Objective, you may then use additional Organizational leverage to the extent needed.

My final point is rooted in the concept well espoused by Jack Welch that some managers in the workplace may not be of the caliber that your Organization would seek to retain to reach its long-term Objectives. That being said, sometimes the high level of collaboration required for a Project Team to successfully achieve its Objective is underdeveloped in (or rejected by) a percentage of managers in your Organization. Upon having the deficiency brought to their attention, many individuals will accept the feedback, seek self-improvement, and grow as Leaders from the experience. But those individuals who choose to remain islands unchanged will find themselves islands outside of the Organization. Bon voyage!