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Watch out for compliance program ‘scope creep’

Ellen Hunt ( is Principal Consultant and Advisor for Spark Compliance Consulting in Chicago, Illinois, USA. Melanie Sponholz ( is Chief Compliance Officer for WCP Healthcare in Chicago. Adam Balfour ( is a Vice President and General Counsel for Corporate Compliance and Latin America for Bridgestone Americas in Nashville, Tennessee, USA.

The “boiling frog effect” suggests that a frog placed in warm water that is gradually increased to a boil will not realize what is going on until it is too late. The gradual, incremental changes result in a cumulative impact that brings serious and damaging consequences. “Scope creep” is similar to the boiling frog effect and is something that ethics and compliance professionals need to be on the lookout for and carefully manage to ensure that ever-increasing responsibilities and workloads do not result in serious and damaging consequences for the ethics and compliance program, the organization, other employees, or the ethics and compliance practitioner (both professionally and personally).

In this article, we will explain what scope creep is, how to intentionally choose opportunities that will provide for good outcomes, and how to effectively say “no” to others. While we frequently refer to the chief ethics and compliance officer (CECO) in this article, we believe scope creep is an issue for many ethics and compliance professionals, so our guidance applies to all professionals.

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