By Adam Turteltaub
adam.turteltaub@corporatecompliance.org
My adult life has been filled with a constant search for shirts.
At nearly six and a half feet tall, and with a sleeve length of 37 inches, I find it difficult to find long sleeves that are long enough. Too often I have tried on a shirt only to discover that it turns me into Adam the Monkey Boy.
But lately things have changed. After countless “Brooks Brother Outlets or Nothing” years, I discovered J. Crew Factory has a wonderful selection of shirts in my size and a never-ending series of sales. I immediately dove in greedily, grabbing all I could in the belief that this cornucopia of casual wear couldn’t possibly last.
With each sale offer I seemed to buy another shirt, and the other day, as I pondered buying yet more, I discovered something utterly improbable. For the first time in my adult life, I have too many shirts. I’m about four away from needing a crowbar to separate the hangers.
So I vowed to stop buying more. But I can’t help but look every time I get an email announcing the latest deal.
Too often we find ourselves in a thinking gap of this sort, realizing too late that we’re still trying to solve a problem that has already been solved – in particular if it is a problem that at one time seemed intractable. We want to keep increasing our effort and resources when an increase may no longer be required.
A periodic compliance program assessment helps prevent that. It forces you to stop, take a step back and ask: have I over-invested in one area of my compliance program? Have I neglected another part? Is there something I hadn’t thought of? Is the problem I have been solving for still a problem, and is it time I increased my focus on something else?
“One of the more difficult decisions we face as compliance professionals is knowing when to say when – when are additional resources no longer necessary?” observed Rebecca Walker, who spoke about program assessments at the 2015 Compliance & Ethics Institute. “In light of the fact that resources are always limited, that is a talent worth developing. And when we can tailor program elements not only to the risks that the organization faces but also to the particular roles of various employees within the organization, then we can significantly increase program efficiencies. “
Assessments can be enormously helpful in forcing us to stop and go through that exercise, and ultimately keep us from filling our compliance closet with things we don’t really need.
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When is enough enough? Your post is thought-provoking and got me thinking what initiatives I should revisit. Thanks!
Adam makes a great point about the value of assessments. Periodic, independent assessments of both the E&C Program and its impact on culture are not only healthy and valuable to the organization, they are NECESSARY if a company would like to receive preferential treatment under the Sentencing Guidelines.
This article is spot on Adams analogy of buying shirts is a clear example of working a problem to death. We need a reminder to prioritize while broadening our scope/focus. Tom
Thanks for the article, Adam. Excellent and innovative analogy, and an thought-provoking point!
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