What is a Culture of Integrity & How Do We Get There?

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15 Questions with Roy Snell, Retiring CEO of the Society of Corporate Ethics & Compliance and How to Implement a Culture of Compliance in Your Own Workplace

If compliance is your profession, or you’ve never heard of it before you should read this article. Read it because the compliance community will directly impact the integrity of the companies you and your families work at, buy from, and share community with.

Compliance is the department within organizations that shoulders all responsibility for the company’s moral and ethical integrity. Infamous public corporate and business scandals can frequently be traced back to either a failure in adherence to compliance codes of conduct OR an absence of necessary and impactful compliance codes within the organization. What happened that enabled the bad behavior? What processes and systems need to be put in place to prevent it from happening again?

I first met Roy at an SCCE conference where I’d been invited to speak.

Roy’s perspective is seminal to my understanding of contemporary compliance practice and its exciting potential. Fundamentally, his passion for integrity inspired me and defined the course of my career. I am now a compliance keynote speaker, and I employ compliance best practices in my roles as both an executive communication coach and technology leader at a digital agency.

Above: Roy gifted me my trendy oversized  “Compliance Professionals” Jersey at 2017’s Compliance and Ethics Institute. It hangs in my closet as a badge of honor.              

The connective tissue of the world is people talking to people, software talking to software, humans talking to software which talks to humans (e.g. an email), and the loops go on. Each of these interactions is fraught with opportunities for miscommunication, misinterpretation, and a breakdown of understanding. Those who are responsible for ensuring companies behave ethically bare a huge responsibility. Success is only possible when the messages of these individuals are heard by the organization and supported by leaders and stakeholders.

We are currently seeing a seismic shift in the communication methods employed by leaders as they endeavor to inspire self-regulation within communities. People have long believed that effective communication is based upon immutable qualities like innate sociability, problem-solving acumen, and leadership instincts. However, we’ve learned that effective communication can be built and nourished within communities and companies alike. Compliance professionals play a pivotal role in this new climate. The role of compliance is no longer just numerical code benchmarks; it now encompasses a conversation around communication, company culture, and emotional intelligence in the workplace.

Fifteen questions with Roy Snell, the longtime CEO of the SCCE, and it becomes clear how this profession has evolved… and why you should get on board for what’s to come:

Left: Roy’s keynote address at 2017’s Compliance and Ethics Institute in Las Vegas.
  1. KYLE: Why did you get involved in compliance?

ROY SNELL: Like many, I wandered into the profession unwittingly. My CEO was walking down the hall with me reading excerpts of a corporate integrity agreement in 1995 and said, “They are being forced to hire a compliance officer. Maybe we should do it before we are forced to, why don’t you be our compliance officer?” I said sure knowing nothing and then became engrossed in the profession.

  1. KYLE: What is one word you want to be associated with compliance?

ROY SNELL: Integrity. We don’t use that word enough. I would like to replace the use of the word ethics. The definition of integrity is clear. The definition of the word ethics has been hijacked by social and political extremists.

  1. KYLE: I’ve heard the word “checkbox compliance” a lot. What does that phrase mean to you?

ROY SNELL: Check the box compliance is when someone gets a list of things that you are supposed to have in a compliance program and do them one at a time and check it off their list of to do’s.  Building an ethical culture is far more organic than that. Preventing, finding and fixing ethical and regulatory problems is far more organic than that. You have to do things that engage people and get to a much deeper understanding as to why it’s all so important.  

  1. KYLE: Why do compliance programs fail?

ROY SNELL: Lack of support from leadership, insufficient resources, inexperienced or

uneducated compliance officers and interference from people who don’t want to deal with problems.

  1.  KYLE: How is compliance evolving to encompass conversations about company culture and communication?

ROY SNELL: Leaders are watching their peers lose their jobs, careers and a great deal over ethical and regulatory failures caused by their employees.  Leaders are doing a better job of telling their employees that they have to be committed to the organization’s Compliance and Ethics programs. Good leaders are building this message into their regular communication any chance they get.  

  1. KYLE: What interpersonal skills make a good compliance professional an exceptional compliance professional?

ROY SNELL: Negotiation, compromise, collaboration, motivation, influence… we need it all. This is a complex job. Compliance with the rule of law and behaving ethically at all times is more work for all employees.  Finding and fixing problems involves pain and therefore people have to be able to go beyond their comfort zone. All that requires the compliance and ethics officer to have mad interpersonal skills.

  1. KYLE: What is the biggest interpersonal challenge that prevents the success of a compliance program?

ROY SNELL: Influence.  What MSU, PSU, Wells Fargo and many others lacked was one person with enough ability to influence others to fix a known problem when it was found rather than 10 years later.

  1. KYLE: Why is communication a necessary interpersonal skill for a compliance program to be effective and successful?

ROY SNELL: We have enough lawyers, auditors, risk managers and ethicists.  What we are missing is coordinated enterprise wide communication skills. Compliance and Ethics officers need better interpersonal skills to get the attention of the employees.  We don’t need more technical expertise, we need more communication skills involved in this process of complying with the rule of law and ethical expectations.

  1. KYLE: In today’s world, with a company’s reputation ready to spread like wildfire across social media, does that make companies pay more attention to compliance?  

ROY SNELL: Social media may have done more for compliance and ethics than anyone realizes.  It’s much easier to ignore problems if there are no consequences. They may fear a negative reaction on social media more than the enforcement community.  

  1. KYLE: Do you think there is more public awareness of compliance? If so, why do you think it’s gaining more attention?

ROY SNELL: All the big organizational failures are helping people understand there are problems but the press and social media are not asking or talking about the solution.  It’s getting better slowly as schools teach students about compliance and ethics programs but that is going to take a few more years to help as the younger people get into leadership roles. It’s getting better but it’s very slow.

  1. KYLE: What’s your advice to recent college graduates who want to have a positive impact on the world?

ROY SNELL: I think this new generation has all the right stuff.  I have 4 twenty-something daughters and met 100’s of people from that generation. They see our old problems without bias.  All they have to do is keep heading where they are going and have the courage to believe that they could be smarter than their elders who have come to rationalize bad behavior.  The best advice I could have right now is that the ends never justify the means if the means are unethical or not compliant with the rule of law.

  1. KYLE: What kind of college background or degree would make me a good fit to consider compliance as a future profession or to be involved in the community?

ROY SNELL: The degree to me is irrelevant.  It’s the interpersonal skills that are important.  I would study the elements of a compliance program such as auditing, investigation, etc.  

  1. KYLE: If I am an artist, or creative, is compliance a profession or community that I could be involved in?

ROY SNELL: I have seen artists and creative people do exceptionally well in compliance and ethics departments.   Weak people don’t do well and neither do people who are all up in everyone’s face all the time. The job requires balance.   The job requires a high emotional IQ, not high emotion.

  1. KYLE: What does emotional intelligence have to do with compliance?

ROY SNELL: It’s everything because it’s a very stressful job.  Everyone around you goes bust when there is a real problem. They even go crazy when someone thinks there is a problem and there isn’t.  Our job is to keep people from overreacting and underreacting. High emotional intelligence is critical because so few people have it when problems occur.  

  1. KYLE: How can a layperson with no experience in compliance get involved in the community?

ROY SNELL: I would consider getting into a compliance department using some experience in one element of a compliance and ethics program such as education, communication, audit, risk, etc.  You don’t need to know it all to get into to the compliance and ethics field.

Compliance is the hidden gem within corporations that supports integrity. The future of the world for generations to come lies in the integrity of the culture of companies who are shaping it. Idealists, dreamers, and changemakers alike can have a space in the profession to determine what and how compliance can look and function– and that’s who I hope will get involved in compliance.

Bringing It Home: Implementing a Culture of Compliance at a Startup

Previously, large companies and corporations were the ones with the budgets to consider compliance. Now, smaller businesses like Jackrabbit, the digital agency I help lead in Austin, Texas, are setting up our cultures and community for long-term success. Our CEO, Jonathan Rosenberg, and I have taken the mission of integrity and insights gleaned from the benefit of having Roy as a presence in my life and bridged it into investing in a culture of communication by creating systems for transparency and accountability, starting with ourselves.

For example, during a trying time of change, as a leadership team we put out an anonymous Q&A box. In a weekly open forum, we read and answered every question from our team members out loud in front of the group. It has been a humbling opportunity for us to be vulnerable, exposed, and radically candid. In turn, this empowered our team members to demonstrate the same vulnerability and accountability with each other.

Above: Jackrabbit’s founder & CEO, Jonathan Rosenberg, answering questions.

Experiences that kindle authenticity and vulnerability in the workplace will serve team members in all aspects of their personal and professional lives. Our long-term intentions echo Roy’s insights: don’t wait for compliance to become a problem. Use it as inspiration to cultivate the strong community and team that will make your business‒ and ultimately the world‒ better.

Kyle Zamcheck is an executive communication coach and technology industry leader. As Chief Operating Officer at Jackrabbit her focus is on the intersection of humans and technology.  Her growing list of clients includes corporate business leaders, startup CEOs, fortune 500 companies such as Google, and main stage speakers from Silicon Valley to The White House. She can be reached at kyle@jackrabbitmobile.com

3 COMMENTS

  1. Informative, candid and impressive piece. That part about ‘The best advice I could have right now is that the ends never justify the means if the means are unethical or not compliant with the rule of law‘ -captured my attention as I think about companies who do whatever it takes to accomplish their bottom line.
    Thank you for reinforcing the not too obvious.
    Kind regards,

  2. Certainly , becoming a compliance professional requires a lot of training and learning considering how vital the role of a compliance officer or the compliance profession is to organizations , governments and the society as a whole.. From my training experience I will forever remain grateful to my mentors and trainers for their patience and tolerance even at my lowest points , and that has taught me the importance of patience in my practice as a compliant officer.. My greatest desire however is to be the most effective , efficient and productive professional dueling my journey and endeavor as a compliance professional and sincerely be very excited to achieve that goal with the continuous support and guidance from my partners, mentors , trainers,, investors, and my entire workforce.. I have realized the act of ENFORCEMENT as a very key element of the compliance profession and will very much be eager to ensure that our collective values as compliance professionals and the compliance profession is attained by eliminating and exterminating all undesirable elements and conducts from our society as soon as possible for a much healthier and better world.

  3. Roy, congratulations on your retirement. Your insight and foresight will be a great loss to the organization. Your point that “The job requires a high emotional IQ, not high emotion”, is actually my favorite ‘life-challenge’ for my audit/compliance shop. Getting emotionally charged when trying to articulate or solve a challenge opens the door for missing the root-cause, and often the symptom not the cause is addressed or brought fort for remedy.

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