Fixing Compliance with a Few Screws

By Ling-Ling Nie
Ling-Ling.Nie@us.panasonic.com

Earlier this summer, I broke my collarbone in a cycling accident.  Compliance tip: Always wear your helmet!  I now have a titanium plate with six screws sitting silently inside my right shoulder.  Anyone who has had collarbone surgery can probably relate to the seemingly endless days spent lying in bed, immobilized by a sling, and covered in ice packs.  The silver lining is that I had a lot of time to think.  About everything.  Including compliance.

Even before my cycling misadventure, I often thought long and hard about my compliance role at my company.  I have heard the role compared to that of a lifeguard, a police officer, a judge, and even a parent (yes, true story).  Interestingly, what I have learned over the course of my career is that all of these comparisons are, in fact, accurate.  How the compliance function is characterized all depends upon your particular company, industry, risks presented, and the culture.  The success of your compliance program hinges on identifying and playing the role that will be most effective within your organization.

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To make things even more interesting, the role can often transform and morph as the company’s business changes and grows.  And here is where my ride-gone-wrong has inspired me.  I’m adding “titanium plate and screws” to the list of compliance role characterizations.  Stay with me now.  A company recovering from criminal or civil compliance penalties often feels weak or broken.  The atmosphere is filled with uncertainty and there can be misalignment between leaders and their employees.  How can you put the company back on the road to compliance success?  The answer is to present yourself as a solid structure with clearly defined screws…ahem, policies and programs, under which the company and its people can find direction on how to realign to prevent future missteps.   As adjustments are made to business operations and fractures across internal controls are healed, you will maximize your effectiveness by serving as the framework that reminds everyone why compliance is so important and provide them with the tools to make it a priority.

Once you have helped restore the company’s confidence in its compliance procedures, you will need to transform back into whichever role will help maintain it.  This could very well be a lifeguard or a parent.  But hopefully, if all goes well, it will never be another metal plate, pin, or screw.