Chief ethics and compliance officers make tough decisions every day—among them, how to allocate limited compliance resources, who to appoint as their most trusted compliance liaisons, and how to nurture a speak-up culture that values ethical behavior and awards (not punishes) acts of integrity.
The resignations of Walter Shaub as director of the U.S. Office of Government Ethics and Hui Chen as compliance counsel for the U.S. Department of Justice—both of whom have criticized President Trump for his questionable and unethical leadership style—raises several thought-provoking questions among the ethics and compliance community at large.
The main question for all ethics and compliance professionals at its core is, “What would you do?”
As President Trump’s business practices and philosophies continue to come under scrutiny, now is not the time for the U.S. ethics and compliance community to step down, but rather to step up and show that unethical business practices are not to be condoned, but condemned.
What would you do if you worked for a CEO who threatened and then fired employees for speaking out?
What would you do if the CEO refused to obey the company’s policies and procedures on conflicts-of-interest?
What would you do if senior-level leadership refused to make full and timely disclosures of personal interests and beneficial ownership?
What would you do if the CEO did not believe in conducting due diligence on the company’s assets?
What would you do if the company, under investigation for questionable practices, did not have the freedom to conduct an independent investigation, because the CEO under investigation fired the legal team?
What would you do if your best ethics and compliance liaisons were quitting left and right because of the CEO, who shows little to no interest in replacing their roles?
What would you do if you were informed that the CEO was cutting the compliance budget in half because compliance simply isn’t a priority?
Any ethics and compliance officer worth his or her salt knows how critical it is to be supported by the right tone from the top. The tone coming from the White House is clear: President Trump’s fiscal year 2018 budget proposal slashed the Department of Justice budget by $1.1 billion. The Securities and Exchange Commission has implemented a hiring freeze. And in Attorney General Jeff Sessions’ memo to federal prosecutors, the focus was strictly on “targeting violent crime,” not white-collar crime.
As President Trump’s business practices and philosophies continue to come under scrutiny, now is not the time for the U.S. ethics and compliance community to step down, but rather to step up and show that unethical business practices are not to be condoned, but condemned.
The stage is set. The curtain is up. Now, it’s time for America’s true ethics and compliance leaders to play a leading role on the global stage.
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