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Innovation in Compliance with Tom Fox

Aug 14, 2018

Ellen Hunt in the Chief Audit Executive and Ethics and Compliance Officer at AARP. Her experience in the industry is impressive: running departments, reporting to governance, handling investigations, designing education, and more. She’s been featured in numerous Ethics and Compliance publications and she regularly contributes to others. Ellen will be presenting at Converge18, and today’s episode is a preview of the amazing content she has to share.

  • An ethics & compliance program cannot be effective if it doesn’t have a Chief Ethics & Compliance Office that can give people the bad news. It’s clear that the drafters of the Federal Sentencing Guidelines knew and understood this and more importantly, by sending the time to position the CECO with assess to the Board, knew this was a critical hallmark of an effective plan. Access to the Board, of course, goes hand and glove with having the right resources and also being independent. In order for the E&C program to be effective, there are three things the CECO needs to leverage.
  • Trust: As the CECO, you have to build trust with your Board and your C-Suite. They need to know you are a practical and reasonable business person who is there to help resolve problems, not to embarrass them. What you do as the CECO reflects on their leadership, and you need to be sensitive to that whenever you talk to the Board or the C-Suite about an issue. Be reasonable in by raising issues discreetly, being open to all solutions, and being practical. Thomas Jefferson put it this way: “In matters of style, swim with the current; in matters of principle, stand like a rock.”
  • Communication: You’ve heard of ‘location, location, location’ in real estate, and compliance has a similar mantra: ‘communication, communication, communication.’ You need to be communicating with your Board and C-Suite. Remember, these are smart folks and they want to do a good job. Articles and information on how the Board and C-suite can improve the E&C program can go a long way in establishing a relationship where they see the CECO as a resource, and the E&C program as a critical component of the organization’s risk management program.
  • Tone: The ‘tone at the top’ is incredibly important and needs a reset. Memos sent from the Board and C-Suite about how they value the E&C program don’t actually percolate through the organization. They don’t inspire people and guarantee that everyone will stay in compliance. In reality, most employees will ever meet a Board member and the Board member will never know who the employees are, so a simple memo isn’t going to mean a lot. It might also be true for the C-Suite, so a ‘fly by’ mention in some town hall or other meeting doesn’t set the tone for employees to embrace the E&C program.
  • The greatest impact executives can have on how they lead corporate culture is how they interact every day with their staff and others. If they show that they are not above the Code, if they ask their folks to check the Code and check in with the Compliance office, if they include the compliance team when there are major initiatives and projects, and if they are uniform and consistent in enforcing discipline, this sets the tone not just at the top but throughout.

Converge18 Conference

Make plans to attend Converge18 and listen as Ellen goes deeper into what you’ve heard in this episode. The conference also has a fantastic agenda for Ethics and Compliance leaders, Legal professionals, human resource leaders, and C-Level leaders. There’s 18 breakout sessions, 12 roundtables, 5 general sessions, 2 keynotes, and an inspirational speaker.

Make sure to use the code, TOMFOXVIP,  to get a great discount on this year’s Converge18!