Compliance in Sarajevo

Downtown Sarajevo Bosnia2014-snell-roy-speaking-headshot-200By Roy Snell

I received an email from a consultant in Sarajevo Bosnia-Herzegovina asking me to come speak at a compliance conference that was likely to be the first-ever compliance conference in Bosnia. Rather than go to big cities, and meet big and powerful people for 9 course dinners, I prefer to say yes to people like Bojan (pronounced Boyan).

Bojan lives in Sarajevo and he is a pioneer in compliance in a country that has yet to embrace compliance. Helping compliance professionals who struggle to get help and are sowing the seeds of compliance programs in far flung places is what I prefer to do. I hit the jackpot. As I stood at the carousel waiting for my luggage, something hit me that would have hit a normal human being the moment they received the unsolicited email from a stranger in such a far flung place, “What if this all goes horribly wrong?” I will admit it, I am a little slow in regard to these sorts of things. By definition, I cannot help people who may need it the most if I were to give careful consideration to these sorts of decisions. I was 5033 miles from home and it was far too late to reconsider it. Moments later I met Bojan and Visnja and had one of the most, if not the most, rewarding experiences of my professional career.

I later met the rest of their consulting group, Mila, Rusmir, and Faris. They work out of a small single room office in war-torn Sarajevo. In the course of my visit, I probably met most everyone involved in compliance in Sarajevo. Three people visited our website from Bosnia in 2015 and I probably know all three of those people now. The most amazing of the many amazing stories was the fact that Bojan and Visnja wrote a whistleblower protection law that was recently passed by their government. They are average citizens making a difference. Actually, there is nothing average about these people.

Bojan and his staff have little, but appeared to be very happy to me. They laugh and joke, usually at Bojan’s expense. He is an unassuming, strong leader who is also very humble. As we walked the streets of downtown Sarajevo people would stop and greet him. He is very well known.  Bojan has a big personality, but the greeting of these people in the street was interesting. It was a very quiet, respectful greeting. It was unique in a way that is hard to describe, but it said a lot about his humble and principled nature. It was odd to me that a guy who had very little had so much respect and was so well known. I believe that he was respected for his action rather than his power, money, or place in society. He could have probably chosen a different path and had more money, power, and title but instead he chose to do the right thing regardless of what it brought him. He is a principle-based, self-deprecating, charismatic leader.

At one point he told me that we looked alike. We did, but he was a 40 year old version of me. He said if he took me to his village they would think I was born there and that we were brothers. He went on to say that we both had features of a Neanderthal and made a couple other comments that nearly brought Visnja and Mila to tears laughing. The most interesting aspect of these people is that they are very comfortable getting by with very little. They are principled people who could teach us all a lot about “doing the right thing.”

I looked out the window of the car at several bullet-riddled buildings as they told me about the most recent war. The economy there is not capable of fixing what is broken, even though it was broken some time ago. They took me to the street corner where WWI was started by a single gunshot from a 16 year old boy. I was told of the occupation of Bosnia by several different empires over the last few hundred years. I have seen people who were in the wrong place at the wrong time, but this was an entire country in the wrong place at the wrong time. They are essentially at the world’s intersection of different. Many diverse cultures surround them and it is where the east meets the west. When tensions arise in this part of the world… they arise at the foot of the citizens of Sarajevo. They could not get out of the way of trouble if they wanted to.

Visnja told me about the time she was shot by a sniper during the war. Sarajevo is surrounded by mountains. Snipers would sit in nearby hills hoping to pick off men, women, and children. Apparently this had gone on for a long time. Bojan told me that, “Tomorrow they will determine the guilt or innocence of the Butcher of Belgrade, Radovan Karadžić, who was responsible for the deaths of many people from this area.” Bojan said, “The people of Sarajevo were nervous about the outcome.”  Karadžić was found guilty of most charges, and after his appeal he will likely spend the rest of his life in jail. On the day of the UN’s decision regarding his guilt I saw no celebration. No one I met in the next two days said a word about it. They simply wanted justice. To them, there was nothing to celebrate.

I met with the President of a large University who was implementing a business ethics class. I encouraged him and his staff to add compliance. We met with an association formed by pharmaceutical companies whose main mission was to encourage the government to implement more regulations for their industry. If there is an alternative universe, I felt I was in it. In what country do citizens write whistleblower protection laws and have pharmaceutical companies banding together to call for more regulation in their industry? As it turns out the answer to that question is Sarajevo, Bosnia Herzegovina.

Everyone they introduced to me, many who were ordinary citizens, were trying to make their world a better place by implementing compliance programs. One of Bojan’s clients is the Ministry of Defense whose leadership is committed to solving some of their problems through the implementation of compliance programs. I met the Inspector General for the Ministry of Defense whose job is much like a compliance officer. Bojan helped with this progress. His commitment to compliance programs is very strong. But many other parts of this country are a long way from where they want to be. We take compliance for granted and some in the US see compliance as an inconvenience. These people see compliance programs as the solution.

I also met someone from their Healthcare Ministry. That night Bojan received an email from her suggesting they get together to talk about implementing some regulation encouraging healthcare organizations to adopt compliance programs. He beamed as he read the email. Despite having a single payer government run system, their healthcare regulatory problems are identical to those in the US. There are problems with the accuracy of billing for healthcare services. I have long held the belief that we can keep beating the insurance companies senseless and trying different forms of government run healthcare and it will not solve the problems of healthcare. Before we try another multibillion dollar change to our healthcare system it would serve us well to spend some time in other countries that have such systems. My view is that the problem is at the source and the best fix is to implement compliance programs at the source.

I spoke at their one-day conference. There were compliance professionals from many of the surrounding countries. The people and the questions they asked were identical to every conference we have ever had. They had the same questions and concerns. They enjoyed the networking and the profound feeling that occurs at many compliance conferences… “I am not alone.” It reminded me of the first meeting that we held in Minneapolis 20 years ago, at which we started HCCA and subsequently SCCE. One attendee asked me if compliance professionals should get involved in setting salaries for their pharmaceutical sales representatives. It was the same question I recently received in the US.  All the questions and concerns were the same.  It was as if I was attending a compliance conference in London or Pittsburg.

The minute I got back to the US, I told Joe Murphy about the whole experience and suggested he help them. I told the people in Sarajevo that Joe would likely be interested in helping. I told the people in Sarajevo that Joe was the only person in the world that has experience helping governments and countries implement some version of the US Federal Sentencing Guidelines section on compliance programs. Joe is the only person I have ever met who is the only expert in the world on a particular subject. He is the only person who has directly or indirectly helped many countries encourage the implementation of compliance programs. It is rare that a person who is the only expert in the world will drop everything to help people who cannot afford his help. Joe often helps others at his own expense. Joe and I share the same perspective on this. We are looking for results. As small as the gains may be, we are looking to sow the seeds of compliance even if we may not achieve the desired results until we are gone. He too would rather spend time in a place like Sarajevo helping people no one else is helping. Viva Sarajevo. Viva Bojan and his merry band of compliance professionals.

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