The Accidental Compliance Professional

This is a list of things I commit to as a compliance professional. It’s not an exact science, an exhaustive list, or a standard―it’s just my perspective. Use this credo as a starting point for your own compliance credo.

• I prevent, find, and fix ethical and regulatory problems and strengthen my organization’s ethical culture using all elements of a compliance program.

• I am concerned about all risk areas and laws.

• I base my compliance program on Chapter 8 of the Federal Sentencing Guidelines.

• I regularly reread the Code of Professional Ethics for Compliance and Ethics Professionals to reset my focus.

• I am conflict-free, unbiased, and impartial.

• I seek support from my peers and I seek to support my peers

• Interpersonal skills such as collaboration, negotiation, and influence are keys to my success. I fully commit to having a strong emotional IQ.

• I help departments minimize the impact of compliance on business effectiveness.

• I help leadership effusively communicate their commitment to compliance and ethics.

• I regularly ask people throughout the company if they are aware of any problems. I don’t just rely on the hotline. I make it easy for people to report issues.

• I regularly conduct compliance education sessions and then follow up with a few private interviews asking if employees are aware of any problems identified in the training.

• I protect those who report issues and facilitate trusted anonymous reporting.

• I use facts and the truth, and effect due process to protect those who are falsely accused.

• I will work with the organization’s leadership to address known issues. I gather facts and tell leadership the truth. I’m not influenced by internal politics. I protect leadership from bad advisors and seek to keep all employees out of trouble. I report all material impediments to the implementation of an effective compliance program to leadership.

• I will report to a subcommittee of the board on a quarterly basis, the whole board annually, and regularly provide education to the board.

• I avoid finger-pointing and lecturing. I will recommend discipline when warranted.

• I consider risks created by partners, advisors, contractors, and third-party companies.

• I work with in-house and outside counsel―I don’t work for them.

• I am aware that conflicts of interest create problems and can be the enemy of resolving problems. I seek to remove or effectively manage conflicts of interest when possible.

• I believe I need a seat at the table to prevent problems before they start.

• I will not participate in misconduct. Integrity is my core principle and I will not compromise it, even to right a wrong.

• I wait until a comprehensive investigation is completed before discussing specific details or recommendations, but will keep leadership generally aware of my progress.

• I only discuss possible ethical and regulatory issues with those who need to be involved.

• I am willing to delegate any compliance activity, but will assure it gets done correctly.

• I help everyone in the company take on some responsibility for compliance.

• I use outside specialists, not generalists, for high-risk activities.

• I cannot be responsible for both operations and compliance for the same area.

• If I discover an unrelated problem during an investigation, I will investigate it thoroughly.

• I do not let the pain from fixing a problem deter me and I will resolve it internally.