A large part of success for compliance programs at hinges on the chief compliance officer’s ability to shepherd change through the organization. And let’s be honest: managing change is not something many big businesses do well.
I’ve been thinking about that lately because for the last year or so, once a semester I give a guest lecture at a New York University class about change management. Technically that subject falls under the discipline of human resources, but every chief compliance officer I meet cares about organizational behavior quite deeply. You can’t win over employees’ hearts, you can’t get them to like ethics and compliance programs, unless you have a well-designed plan to change how they all work. Otherwise you’re just running around in circles, spouting values from the mission statement and imposing more controls when employees ignore said values.
