This topic really has me frustrated. I understand that the problem I am discussing is not a problem for every organization and doesn’t apply to all of you. But the problem occurs often enough in our profession to be worrisome. And it eventually will go from worrisome to terrifying if this problem grows rather than shrinks.
There is an increasing tendency for some people to become so politically correct that they are now making bad decisions. Some people feel that the best way to make change is to do nothing more than complain. There are an abundance of whiners and a growing number of apologists in our culture. This drift in our culture could affect the compliance profession. Compliance officers implementing compliance programs receive criticism because we are doing something about ethical and regulatory problems. Our profession was created because those who came before us did nothing, like Penn State University, Enron, and many others. People did nothing in the past because if they did something, they would receive criticism by standing up to those who wanted to do wrong. Our profession was created to do something about ethical and regulatory problems, we are doing something about it, and we are receiving criticism occasionally. We are receiving the same criticism that caused those who came before us to burying their head in the sand. It would be ironic if our profession did what those did who came before us, the same thing that caused society to insist our profession be created in the first place. It would also be tragic.
And now, because of the growing culture of political correctness and propensity to apologize, some people apologize for the things that are necessary to implement an effective compliance program. For example, some people who do nothing but complain, and refused to put a shoulder to the wheel… call compliance and ethics officers cops. Then some people in our profession, under pressure and already weakened by the politically correct apologetic culture, spend a great deal of time trying to get people to like the compliance department. It sounds like a good plan, but instead of preventing, finding, and fixing problems, they are running around apologizing and doing things to be liked. Trying to get people to like you and the compliance and ethics program does very little to prevent, find, and fix problems. Educating, auditing, investigating, etc. helps prevent, find, and fix problems. Apologizing doesn’t find and fix problems. That’s what the people who came before us did. It did not work.
The alternative I propose is to tell people the truth. “Of course we are not cops, but I’m not going to spend the majority of my day trying to make you like me, or our compliance and ethics efforts. I am going to spend my day preventing, finding, and fixing problems so our organization doesn’t end up on the front page of the newspaper and with financially crippling penalties. Some of the things that I have to do to accomplish that goal will be uncomfortable. I have to educate, which will take some of your time. I have to audit, and that is going to cause you to think I am questioning you. I may have to occasionally investigate you, and that could make you uncomfortable. If I don’t do any of this, we will end up like the many other companies that have a terrible culture, and crippling fines and penalties. I am not going to apologize for doing the right thing, but rather I am going tell you the truth and help you understand. The people who you should be frustrated with are the apologists who came before me and hurt our culture and put us at financial risk.”
Do not apologize. Do not change to appease people who just complain and don’t help to fix the problem. Be kind. Be nice. Be empathetic. Be fair. Be understanding. Listen to others. Be mature and as charming as you can be. Improve every chance you get. But do not apologize for the difficult things that must be done to root out those who would hurt your culture or your organization’s financial strength. Do not apologize for doing the things the apologists refused to do in the past that collectively help ruin the reputation of business leaders and the business community. Instead of apologizing, I suggest you simply do your best to be civil, understanding, and tell people the truth about what we need to do to successfully implement a compliance and ethics program. I suggest rather than turning the other cheek, or apologizing, you look people in the eye and tell them the benefits of an ethical culture and the advantages of preventing regulatory wrong doing. Tell them the truth.
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