Compliance New Year’s Resolutions

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Post By: Adam Turteltaub

Welcome to 2022, and, as far as I’m concerned, the sooner we forget 2020 and 2021 the better (other than the Dodgers winning the 2020 World Series).

As we look to the future, it’s time to make New Year’s resolutions for compliance and ethics programs. Here are mine. Some are things for us to do, and some are things we should stop doing. None involve dieting or exercise:

  • Let’s never again discuss whether ethics is more important than compliance or compliance is more important than ethics. It’s like discussing whether the heart or brain is more important. You can’t live without either one.
  • Let’s never refer to “check-the-box programs”. Do you know of anyone with a check-the-box program? Probably not. And too many outside of compliance think that our programs are just window dressing. Let’s not encourage them.
  • Let’s try and be the most present part of the organization. As people return to the office – Omicron permitting – let’s do our best to be there, too. We are the guardrails of the organization, and the best way to keep things on track is to be there for people. And never discount the value of bumping into someone in the hall. It’s an opportunity to check in and encourage them to raise that nagging thought.
  • At the same time, let’s not neglect remote workers. In fact, now is the time to redouble our focus. If they are at home when more or most of the company is in, they may find themselves feeling disconnected. That’s bad on a personal level, but if they feel disconnected from the culture, then it’s dangerous.
  • Be there for your peers in the profession. As we have resumed doing in person SCCE and HCCA meetings, it’s clear how thrilled people are to be able to sit down and talk with other compliance people, and how much they missed that connection. Make an effort to connect. If you can come to a meeting, great. If you can’t check out the HCCA or SCCE LinkedIn groups or go on HCCAnet or SCCEnet. Or, just pick up the phone and call someone you used to talk with each year at the Institute. Whatever you do, be there for each other.
  • Put a plan in place for when something close to normality returns. Odds are that a lot of things have been pushed off, including a more thorough vetting of your new vendors. You can’t do it all at once, but start planning on what you’ll be doing first, second and third.
  • Be mindful of the stress everyone is under. As my friend Chris Bohjalian so eloquently writes, we are not all fine. We’re all dealing with issues these days. It’s important to remember that and give each other a bit more kindness than usual. But we also need to be vigilant: people under stress don’t always make the best decisions.
  • Be mindful of our own needs. Compliance is often a thankless job, requiring tremendous courage. If you feel things are getting out of hand, give yourself permission to stop, take a breath and get support. That may come from colleagues at work, or it may come from your network.  But reach out to others to get the help you need.
  • Remember that this, too, shall pass. You got through 2020 and 2021. Odds are good you’ll make it through 2022 as well.

Happy New Year. What resolutions do you think we should make?