How to Promote Compliance and Ethics as a Leader

What is clear to me from my time as a Global Head of Compliance, and afterwards in a regional leadership role, is that unless the leaders in a company actively promote a culture of compliance it will not happen. However, it is not always clear to know what to do to promote Compliance and Ethics within the organization as a leader.

Common suggestions are that one should include a Compliance and Ethics slide in one’s presentations in meetings, or one should start each meeting with a minute on Compliance. I think that these suggestions are fine, but they are not always practical, they can be distracting, and I am not convinced of their effectiveness.

So… assuming you have already set aside budget for the Compliance Program and Compliance staff, how can one best promote and improve a culture of Compliance and Ethics throughout the organization as a leader?

Below is my recommendation for what I found to be the most effective method, with an added benefit of improving the overall company culture and giving one the best insight into the state of the company.

I have been privileged to visit 45 countries (and probably double that number of offices) during my time with my current company, and I have probably met more employees than anyone else in the organization. Travelling and meeting staff puts one in a unique position.

I have found that the most beneficial thing I can do is to spend one-on-one time with as many people as possible, and to just sit and talk and listen. I get insight into the state of compliance within a location, but also understand better how the office functions, what the culture is, how motivated and happy the people are, and make a connection with people and give them an opportunity to share their ideas and challenges.

When I travel, I try to meet 10 people for one-on-one interviews from an office / country. Before I travel, I ask for a list of employees at that location, their job titles, and length of service. I then pick a variety of people and ask my contact at the office to set up one-on-one, 30-minute meetings during my time in that location.

It can take a little practice to get comfortable with the process. One only has 30 minutes to put someone at their ease, find out information about them, and impart your opinions and direction / strategy. I am lucky in that I love meeting people and finding out about cultures – this definitely helps – but it can intense and tiring.

My tip is to not start each interview with work topics, but rather with personal ones. Share something personal (not too personal!) about yourself, and then ask them about who they are, their family, where they have worked before, what they like to do in their spare time, what food they like, and what the local specialty is that I simply must try (food is always a good topic!).

And then, periodically, insert questions that are more compliance and work related: how it is to work for the company, what the best and worst things are about working for the company, whether they have ever been asked to do or they have seen something which they felt uncomfortable with, what they would change if they were in charge for a day, whether they think the office is an equal opportunity workplace, and what new things they think the company should be doing. When interviewing employees who have recently joined the company, this is an opportunity to find out why they changed jobs, how the onboarding process was, and whether the company and the job is how they thought it would be.

But be prepared for anything! I have people come in to meet me, sit down, and immediately burst out crying due to a situation which is happening to them at work or in their personal life. Others have come in with an armful of folders of evidence of fraud. Some won’t say anything without their boss in the room (which may tell you something about them or their boss). Some may be angry with you, even though you have never met them before; some may want to complain about pay or working hours. It is all good information to have.

One comment I have received many times during my travels, is the sense of pride and safety that the person has through working for a company which does not require its staff to do unethical things. Many have joined the company specifically because of the reputation it has for ethical business behaviour. This is an important factor for many.

It is a common thought that there are three types of people within a company: 1) those that will always be honest, 2) those that might do something non-compliant if a certain set circumstances and motivation arise, and 3) those that will always be on the lookout for an opportunity to take from the company. This is an oversimplification, but it is a useful one.

It is company culture, personal connections, and that feeling of being part of a family which stop misconduct from those that might do something in certain circumstances. (It is controls, a reporting hotline, and non-retaliation policies which stop those in the final group of people.) For me, company culture is the most important element of the Compliance and Ethics Program, and company culture is determined and influenced most by leaders. To achieve this, leaders need to spend more time with the people that make the company a success.

Best of luck out there! I would love to hear other thoughts on how company culture can be improved in the comments if you would like to share.

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Matthew Paice

#leadership #compliance