Compliance and Ethics: Ideas & Answers. Edition 92

Welcome to the 92nd edition of Compliance and Ethics: Ideas & Answers.

First this week Adam Balfour explores the power of appreciation in “Compliance Incentives - A Simple Thank You.”. Next, Joe Murphy, CCEP interviews Matt Kelly in “An Interview with Mr. Radical Compliance”.?We conclude with our regular feature, Compliance Lite.

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Thank you.

One other point to note. ?From now on this letter will be from "The Editors.” ?We want to be sure that our readers know our material is from all of us, and that everyone gets credit. ?

Compliance Incentives - A Simple Thank You

by Adam Balfour

Incentives to support effective compliance programs are not new, but this is still an area where I feel many organizations could prioritize more and think about the various types of effective incentives available.

While financial rewards and incentives are great for recognizing individuals and sending a message that shows the organization will use its finite financial resources to demonstrate commitment to its values and those employees who support and protect those values, incentives are, and should be, thought of more broadly. Sometimes an incentive doesn’t even have to have a financial cost to it - socially recognizing someone for doing the right thing or even a simple and sincere “thank you” can go a long way.

There are so many ways that a sincere “thank you” can have a positive impact, including:

1. Thanking someone when they have spoken up or otherwise helped in an internal investigation, and explaining how doing so helped. Speaking up can be uncomfortable and cause people to question if they have done the right thing, so thank them and tell them why what they did made a positive difference.

2. Thanking someone who faced a challenging situation and did the right thing, even - and especially - if others did not act in the same way. We are social creatures and influenced by other people more so than written policies, so thank people when they have been alone in acting with integrity.

3. Thanking someone for complying with your policies even if doing so was socially awkward (e.g., they have to turn down a gift or offer of entertainment that does not align with policy, but they don’t want to offend the person who offered them the gift).

4. Thanking someone who asks for help or support, or even wants to talk through something to ensure they not making decisions in isolation. Isolated decision making when coupled with excessive pressure is a recipe for bad things to happen.

5. If you are a manager or leader, thanking someone who has appropriately challenged your idea or raised concerns about the pressure they are under.

Compliance isn’t just about finding out who is acting inappropriately and stopping them - it’s not just the absence of bad things that we care about, but also the presence of good and appropriate actions. If you continuously look for people who are doing the right thing, then you will likely find lots of people to thank.

An Interview with Mr. Radical Compliance – Matt Kelly

by Joe Murphy, CCEP

What is “Radical Compliance” and how did Matt Kelly create this distinctive compliance voice?

At Compliance and Ethics: Ideas & Answers we regularly have video calls among our editors to plan our coverage and focus. Recently we discussed the idea of interviewing Matt Kelly, and we all agreed this would be a good (and fun) step.? I took this up and Matt readily agreed.?

Matt has been in journalism for quite some time.? He had been a newspaper reporter for 5 years before taking the reins at Compliance Week in 2006.? There he embraced the compliance and ethics field and let his curiosity about this subject take over.?

Radical Compliance. After 10 years there as editor (and two before that as a writer) he decided to establish his own medium.? The next step was to come up with a name.? By this point in the compliance & ethics field compliance was a hot topic and anything interesting starting with the word “compliance” seemed to have already been taken.? But he had a radical idea:? just put “radical” before compliance.? This also fit his journalistic style and humorous nature.?

Radical Compliance allows Matt to pursue his own directions, without any boss or anyone paying to subscribe or get promoted in his publication.? It allows him to provide his own, unvarnished opinions. In my experience this includes some very incisive examinations of developments in our field.

Memes? One of the notable characteristics of Radical Compliance is the use of memes.? Was this the result of deep, strategic thinking?? Of course not.? Once while working at Compliance Week he saw a truly odd post on Twitter.? In response he posted a meme in commenting on the post.? He saw the response was good.? Another opportunity came up, and he tried the same step with the same result.? Today it is something we all know to look for in his work.?

A Radical Compliance book?? I observed to Matt that there has been a wave of books coming out in our field in recent years, delivering quite a few clever ideas and useful insights.? I had a hunch Matt would have considered that, and indeed he has.? But he is a journalist with constant curiosity about what is happening today in the field.? So yes, he has lots of notes for a book, but no, riding the waves of current events is taking priority.? In the future?? Stay tuned.?

How big is our field and where is it going? Matt has given some thought to the question of how big our field is, and who is actually in our profession.? He views this as a tough task, given all the variations in our field.? But there is no question it is a big, global field.

Continue reading on our website...

Drew / What Have I Done?

by Karen M. Leet

????????I can’t believe what I’ve done. How could I have made such terrible decisions? To lie and cheat. To steal from the company. To think I was so clever.

??????????? I found a loophole in the accounting. I found a sort of back door to cheat. To steal, actually. I stole money from the company.

??????????? I lied. The higher ups trusted me. But I wasn’t worth their trust.

??????????? And I didn’t even need the money I stole from our company. I don’t even know why I did it. Maybe to prove to myself I could.

??????????? Stupid, stupid, stupid. I never thought I could do such a stupid thing.

??????????? I broke laws, pretending to myself it was OK. I told myself I’d return the money I stole. Later, though. I planned to return it later.

??????????? My friend Jack knew. My former friend. When I got promoted, I dropped him. I thought I’d keep on moving up into better things.

??????????? But when I started to lie and cheat, he knew. I could tell he knew. We’d been close once, and he knew me way too well.

??????????? He never said a word. Not a word. He did not betray me, and I was glad.

??????????? Later, when I got caught and prosecuted, they accused him as well. He could have gone to prison, too—because of me. I spoke up and testified he’d never done anything wrong. Never.

??????????? But my crimes ruined his life, too.

??????????? And my wife. I made a mess of her life.

??????????? And my son. My boy. Trent. My precious son. I think he hates me now. But, to be honest, I deserve it. I let him down. I let everyone down.

??????????? Now my future is gone. My hopes and dreams are gone. Everything I worked for is gone.

??????????? I’m in prison now. Paying the price for my crimes.

??????????? I just can’t believe what I’ve done. To myself. To the company I worked so hard to be part of. To my family and friends.

??????????? So, here I am. In prison. Where I belong for what I’ve done.

??????????? I don’t want to think about any of it. I don’t want to think about the future—what will happen to me, to my family, to any of us.

??????????? In a real way my life is over. I will never again be the person I thought I was. I have no idea who I am or what lies ahead.

??????????? Being in prison marks the end of the life I used to have, the future I expected to have, the person I used to be.

??????????? All I can do is serve my time here, face the consequences of my crimes. No lies to myself now. I lied and cheated, stole and broke laws.

??????????? I deserve what I got. No getting around it.

??????????? But if only I could fix what I’ve done to my family, my friends, the bosses at work who trusted me.

??????????? I can’t fix any of it. I can’t change the past. All I can do is my best to face what I’ve done and do my best in the future. ? 2024 K. Leet?

What do you think?

How can these crimes be stopped?

What can be done?

Who all pays the price?

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