By Roy Snell
roy.snell@corporatecompliance.org
This is intended to be tongue and cheek. I am being facetious. Please don’t hurt me. I just want to make a point about our techniques, commitment, and limitations of getting compliance information and passing it onto leadership. If I was a CEO and I wanted to avoid ending up like Mr. Stump and Wells Fargo, I might consider taking the problem discovery process more seriously. Maybe he should have hired a “Compliance Intelligence Officer.”
The Compliance Intelligence Officer would report to the CEO and no one else. They might even be disguised as some sort of other job, like PR, so they could operate undercover. This person could go to the bar of a restaurant and befriend employees that have had too much to drink, go through garbage, conduct electronic information gathering, hire informants, do stakeouts, and talk to disgruntled employees. How about listening devices, hidden cameras, and sting operations? And instead of rationalizing and defending the inappropriate action, the Compliance Intelligence Officer would build a case to present to leadership as if they were working for the Department of Justice.
OK, now for the disclaimer and the good news. I don’t think we could or should do all of this. We have to find problems in a way that doesn’t cause compliance to look like the Gestapo. However, there are companies like Wells Fargo that are way behind the curve in problem discovery. Or they are not making the case for problem resolution in a way that would cause leadership to fix the problem. Not only are they not the Gestapo, they appear to be about as effective as a 5th grader at finding and fixing problems. Did Wells Fargo really need to act like the Gestapo to find their problem? I don’t think so. Just wandering the halls and politely asking employees if they have seen any wrongdoing… would have caught that problem. How can dozens, maybe 100 people know about the problem at VW and leadership didn’t get the information presented to them in a way that would cause them to fix the problem? I know some skeptics will say that leadership knew and did nothing. I am talking about cases where leadership didn’t know or the problem was presented to them poorly. We need those companies to take this stuff more seriously. Don’t be the Gestapo, but please do something. You are killing us by causing massive regulations and distrust of the business community.
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