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Richard Bistrong: I went to the symphony to learn about compliance

Image courtesy of the Music ParadigmI went to the symphony recently. But not just any symphony. It was the Music Paradigm, described as “as an engaging and unforgettable learning experience for any type of organization.” In my case, it was about compliance. But more about that later.

The audience sits among the orchestra while the conductor runs a series of experiments and asks the audience and orchestral members to share their reflections. It was spontaneous and authentic. And it taught me a lot about compliance.

Aside from hearing some wonderful music -- in my case, C.P.E.  BACH: Sinfonia No. 5 in B Minor (Wq 182, No. 5) -- it's a rare chance to sit with professional musicians and watch them at work.

Every Music Paradigm session is unique. Ours started like any night at the symphony, and it all worked perfectly. I was seated behind a row of second violinists -- you could see their silhouettes, their bows, working in perfect harmony, as if it was one person and a multitude of mirrors. This was achieved by the orchestra’s focus on both the conductor at the podium and their music in front of them.

It was like a good compliance program, where both leadership at the top, and attention to the work at hand, is critical for success. When everyone works in unison, the team functions fluidly, like that row of violins.

Then it all went bad. The conductor instituted what he called a series of “train wrecks.”

First he concentrated on only his music. While technically conducting the orchestra, he never paid attention to them. His baton was in action but his eyes were down on the score. Mechanically, it was perfect. But practically, it took the entire orchestra off the rails.

Even in a compliance program that might be technically correct, with all the boxes ticked, if leadership is not focused on the team -- attuned to their needs, their want for harmony -- then it goes off course.

Another experiment was letting the orchestra do its own thing. The conductor provided little leadership -- about enough to be technically correct but not more. It was frustrating, not only for the audience, having already been spoiled by hearing perfection, but also for the musicians, who reflected (a microphone was passed around) on how upset and nervous they were by the conductor’s lack of direction.

So we see, as with a compliance program, too much latitude, without leadership, also takes the team off course.

In both experiments, the orchestra tried to keep it together, on their own, to compensate for and overcome the lack of direction and clarity. But with time, the music broke down.

It’s what we often hear -- compliance starts strong, con animo, perhaps after an enforcement action, but fades as the bad memories and sense of urgency recede. People forget the pain of the past and slowly the compliance clarity falls apart, like those second violins in front of me.


Richard Bistrong is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLC. He was named one of Ethisphere's 100 Most Influential in Business Ethics for 2015. He consults, writes and speaks about compliance issues. He can be contacted by email here and on twitter @richardbistrong. He'll be a speaker at the FCPA Blog NYC Conference 2016.

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