Knowledge

Compliance (III): Getting Your CEO on Board

If compliance is indeed all about reporting, it may seem easy to implement: it’s just planning. Who is doing what, by when, to get these reports done? You need a bit of organisation and processes. Planning is the easy part, implementing the plan is the tough one. People supposed to provide information have no time, don’t respond to emails, had their hard disk collapse… That’s where compliance becomes really tough. That’s compliance real challenge: getting the data is on the top of your priority list, but giving them is not even on the bottom of the list of the those who possess the information. So, how do you get people to do what they are not interested in doing? That’s the very fundamental question of management. I already struggle to get my 3-year old daughter to eat up her vegetables, so what about lconvincing a 50-year old country manager to do something he does not care about, especially when I have no authority on him? There is no magic solution, but I have an idea though.

Compliance will not work if it looks like yet another initiative from the legal department. Lawyers often have the reputation among business people to be useless troublemakers and out-of-the-loop bureaucrats. The last thing you want to do as a business manager is paying attention to a request by the in-house lawyer. So if compliance looks like a lawyers’ thing, it is dead. Business people are more likely to do something when their boss tells them that it is really, really important for them to do it. And these bosses will only say so if their own boss has told them exactly the same. Eventually, the message must come from the CEO. The CEO must roll up his sleeves, spit in his hands and show some muscle. He must personally sponsor the compliance program, and mean it. The CEO must make the message extremely clear that complying with the compliance program is not optional.

Lesson # 1 in compliance management is that you have to convince your CEO to personally and vigorously sponsor the compliance program. People in the organisation must be convinced in their guts that their boss and ultimately the CEO are deadly serious about compliance. The legal department, or the compliance officer, must appear as the operator of the program, not the owner. To be effective, the program must be CEO-owned and labelled. 

Antoine Henry de Frahan | 11 August 2007 |