When I first stepped into this profession, my title was not “Chief Compliance Officer.” It was “Ethics Officer.” At Westinghouse, I was tasked with launching a program that, at the time, felt experimental: a global, enterprise-wide ethics initiative built not on rules, but on values. I traded in my career as a scientist for something untested, something new. And to my surprise, I had found what I was truly meant to do.

That early experience shaped how I view our amazing profession today. Over the past 30+ years, I have witnessed the pendulum swing from ethics and values to a focus on legal compliance, and now, I hope, it is swinging back toward the middle and finding the right balance. The shift to compliance was understandable. Corporate scandals forced regulators to act, mandating programs to codify oversight and accountability.

But in our zeal to comply, some organizations began losing sight of something essential: the “E” and the people who make or break our organizations. And with that, compliance programs and compliance officers lost some of the organizational clout that early ethics leaders had. Early ethics officers reported to the CEO. Now we see multiple layers of reporting, and I wonder if narrowing our focus is a factor.

About the Author

Carrie Penman is the Chief Risk & Compliance Officer at NAVEX, with a career in compliance that spans over 30 years.

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Why Ethics Still Matters

Compliance, by itself, risks becoming “vicious compliance,” a system so prescriptive that employees do little more than check the boxes. When this happens, they naturally start to search for loopholes rather than asking the fundamental question: What is the right thing to do?

Ethics is not about loopholes; it is about guiding behavior when the rules are unclear. It reminds leaders and employees alike that our responsibility goes beyond regulatory requirements. It extends to our people, our customers, and the communities we serve.

At its best, ethics transforms compliance from a constraint into a culture. And culture, as we know from decades of research, is one of the most powerful determinants of organizational behavior and success.

Listening to the Right Voices

As compliance officers, we serve many organizational constituents. One of the most important lessons I’ve learned is that employees are not the adversary of compliance. Too often, those who speak up (as we ask) are labeled as “whistleblowers,” a term heavy with stigma. I prefer “reporters.” Further, employees with concerns about people-related matters sometimes have their concerns directed back to HR with no follow-up from us. We risk sending the message that compliance is more important than people.

And the data is clear; when they speak up, they’re often right to be concerned. NAVEX benchmark data consistently shows substantiation rates at close to half, underscoring the credibility of employee-raised concerns regardless of the type of issue. Employees are the lifeblood of an ethical culture. Listening to them is one of the most powerful tools we have to detect risk, improve operations, and strengthen trust.

Leadership’s Role in the “E”

Ethics cannot be delegated. It starts with tone at the top and is sustained by example at every level of leadership. Our research shows every year that there are still too many leaders who talk about doing the right thing, but when the pressure is on, they make risky decisions or even impede ethics and compliance professionals.

Ethical leaders don’t just strengthen compliance programs. They build trust, resilience, and performance. They show employees that they are valued participants in a shared mission.

Bring Back the Balance

How do we put focus back on the “E” in Ethics and Compliance?

  • Lead with values. When leaders make ethics visible, employees follow. Tone at the top remains the single most powerful lever we have.
  • Drive the importance of culture. Policies and controls are necessary, but they should support, not replace, a culture of integrity.
  • Value employee voices. Recognize reporters for their desire to strengthen the organization; assume good intent.
  • Balance compliance with judgment. Compliance keeps us in line with regulations – the minimum. Ethics help ensure we are doing the right things right.

Looking Ahead

Our relatively young and exciting ethics and compliance profession will continue to evolve. I believe strongly that if we refocus on ethics and integrity, compliance will follow. Rules will always be part of the equation, but values are what inspire people to live them out.

As I reflect on my wonderful journey, from that first uncertain role as an Ethics Officer to my current role as Chief Risk and Compliance Officer, I remain convinced of one truth: ethics is not a relic of the past. It is the foundation of our future. And if we hold on to that foundation, we won’t just keep our organizations safe; we will help them thrive.

Happy National Compliance Officer Day!

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