As compliance evolves to remain relevant into the future, it could find itself in similar shoes to pop star Justin Timberlake: tasked with bringing sexy back.
But was it ever really sexy to begin with? Maybe the name “compliance” itself has become so antiquated, it puts a negative stamp on how the function is perceived.
At Compliance Week’s recent annual conference, panelists in a session regarding the future of the chief compliance officer discussed how the profession has come a long way from the “Department of No,” but questioned whether that meant it was where it should be today and if it’s headed in the right direction.
“Ideally, I am no longer necessary in 15 years,” said Stephanie Davis, chief ethics and compliance officer at Volkswagen Group of America and a 2019 CW Top Minds recipient. “Now, I don’t think that’s what happens. I don’t think the compliance officer role goes away, but the role 15 years from now, in my opinion, is one of a strategist: of top management, sitting on the board and helping drive the business strategically, whereas everyone else in the company already understands the importance of ethics, compliance, and risk.”
Easier said than done to get a company there, of course. But compliance has at least been trending in that direction. “Fifteen years ago, a lot firms didn’t have risk management,” said Ann Oglanian, president and CEO of the consultancy firm ReGroup. “Maybe they had compliance, but they didn’t have a chief ethics officer. As you’re seeing the trajectory, what are the trends? We’re going to see this kind of collision of these functions, and I don’t know what’s going to win.”
Perhaps all three—compliance, risk management, and ethics—win in such a collision, though. For Davis, who, like many others, heads risk and ethics in addition to compliance at her company, “it’s all a circle,” with each program supporting the other. It means wearing multiple hats at once, but it allows the individual in the role better ground to stand on when communicating his or her message within the company and to the board and C-suite.
Oglanian concurred, but not without a caveat. “I happen to hate the word ‘compliance.’ Compliance is a result. Compliance is not an activity,” she said. “To me, risk is where it all starts.”
Meanwhile, John Krenitsky, senior vice president and CCO at Freddie Mac, focused more on the ethics part of the equation and how it benefits a company beyond the day-to-day level.
“If you look at statistics on the firms that millennials are attracted to today, one of the things they are looking for are firms that have an ethical center,” he said. “If you’re creating that for your firm, you’re going to attract the talented people today who are looking for those jobs. So, you actually make your firm more competitive by having a strong culture.”
Then what is it that those millennials, the actual compliance officers of the future, need to do in order to continue this trend? Among the skills highlighted by the panel include:
Data analytics. “We’ve been saying this for years: You’ve got to understand data analytics,” Davis said. “What I would say is we have to go further than that. You can give me a great program that analyzes all my data, but if it’s [bad] going in, it’s [bad] coming out.” With so much raw data fairly easy to attain, understanding and manipulating it is the key to determining which trends to follow.
Learnability. “I read everything,” Oglanian said. “It is what allows me to not solve problems, but to ask better questions and to see problems other people don’t see.” Instead of sticking to only what you need to know, “learn the business and own that territory.”
Statistical knowledge. “I’m not the most mathematically minded guy,” Krenitsky explained, “… but I understand what the statisticians do, so I can oversee what they’re doing and get an idea of how they’re doing their craft.”
Design thinking. In relation to understanding statistics comes the framing of that information. Instead of just writing it into policies and procedures, find ways to work it into your own personal design of your program. “Actually, that’s the sexy part to me,” Oglanian said.
Communication of the simple. While getting asked the “dumb” questions might seem tedious, it presents an opportunity to instill compliance lessons at the most basic level. “One of the things we’ve started doing that feels kind of rudimentary and silly is these FAQ documents that are very low hanging fruit,” said Davis. “At the end of the day, it’s actually a good conversation because it helps you understand the pulse of the organization.”
Embracing change. Part of the reasoning behind those simple questions is employees’ fear of change, Davis explained. Unfortunately that’s a luxury compliance officers can’t afford, as understanding where the fear is coming from and how to address it becomes part of the job. “You’re going to make 99 percent of the people that you work with uncomfortable, and it’s true, but it teaches you to manage change,” said Oglanian.
Innovation. “We talk about making compliance sexy—it’s never going to be sexy. It’s not ever going to be something people really are excited to do,” said Davis. There are, however, ways to work around that and get the message across through unconventional methods. Popular examples include the use of games or interactive messaging based on real events within the company that engage employees better than simple dictation.
You’ll notice no mention of regulation above. “The technical is assumed,” Oglanian said. “It’s assumed you know it; it’s assumed you’ve mastered it. What’s not assumed are the soft skills.”
And of those, “you have to lead with whatever is your personal strength,” said Krenitsky. “You may not be a brilliant public speaker, but you might be a very good writer. You might be somebody that inspires the CEO of your company to be that ethical leader … I actually think that’s the way to do it.”
Through all those methods, it comes back to communication and elevating the compliance program beyond the fear-based entity that is the “Department of No.” Instead, it should be “more of a holistic, integrity-based compliance program” where trust and working with other areas of the business is the focus in order to keep everyone on the same page, explained Davis.
It might not be sexy, but that strategy has proven in recent years to be successful, and the bet is that it carries into the profession’s future.
“A new day has dawned, and what’s exciting is where that is going to be 15 years from now,” said Oglanian.
Takeaways from Compliance Week 2019
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Soft skills, strategy set to define CCO of future