My two-part series for the FCPA Blog on Beyond Compliance elicited some thoughtful reader feedback. While the comments were as diverse as the professional perspectives of the writers, a few themes surfaced.
Nirav wrote: Therefore the sequence in the diagram should be Ethics -Compliance - Trust (Integrity). In organisations, a policy on Ethics lays the foundation for Compliance.
Donna Boehme wrote: I also think that CCOs need to seriously embrace their roles as ethical culture leaders
Veeresh Malik wrote: Ethics could be re-built but trust once lost never returns, and corporates need to learn this simple lesson, is the way I put it. Compliance is regulatory driven, but if a good corporate can pre-empt the changes forthcoming and stay ahead of the curve with compliance, then that is how growth flourishes.
Charlie Green wrote: You're not likely to find a high-trust institution -- regardless of what that means -- without high levels of high trust individuals.
Alan Franklin wrote: "Compliance" is also voluntary. As we see ongoing bribery is still very prevalent, it is clear that the risk analysis usually favors the bribe.
After giving some close thought to these comments, here are my takeaways:
- A “one size fits all” pattern, as the original chart suggests, may not apply to all organizations.
- Compliance, ethics and trust are culture driven. When they are reduced to merely “programs” they are ineffective.
- Compliance 1.0 does not embrace ethics or trust and progressive organizations are waking up to this and broadening the role.
- Silos must be broken down and chief compliance officers should expand their focus beyond just “the law.”
- High trust cultures can only flourish when high trust leaders are steering the ship… and this requires board support.
- When core values include “high trust,” the role of compliance changes.
Not all organizations will choose trust or ethics as the best way forward. And while this may serve them in the short-term, prospects for long-term survival are reduced. In other words, ignore “risk” at your own peril.
My thanks again to the FCPA Blog for the opportunity to explore the intersection of compliance, ethics and trust with its readers.
Let’s continue the conversation!
Barbara Brooks Kimmel is the CEO and co-founder of Trust Across America-Trust Around the World (here), whose mission is to help organizations build trust. She's also the editor of the Trust Inc. book series and the executive editor of Trust! Magazine.