Being an effective compliance and ethics officer requires a mix of noble traits including technical skills, experience, judgment, courage, and ability to communicate well across disciplines. But some traits not always viewed as noble can nonetheless also be quite useful in making a good compliance officer. Of course, these traits must always be presented in a respectful, professional manner to be truly effective.<\/p>\n
Nosy<\/u><\/strong>. The latest pop slogan of successful sports teams is that each player should \u201cjust do their job.\u201d Good compliance officers, however, don\u2019t \u201cjust do their job.\u201d They are pervasive. They don\u2019t place faith in ignoring a problem with the hope that it will go away. In 2012, it was a compliance officer\u2019s nosiness that saved Morgan Stanley by uncovering the acts of bribery connected to a single employee. This compliance officer decided, despite documentation in support of certain unusual personal expense reports, a closer look was warranted, thus uncovering fabrications by the ultimately convicted executive. That compliance officer, and Morgan Stanley\u2019s robust compliance program, spared the entity untold amounts in fines, penalties, legal and accounting fees, and reputational damages. Such nosy compliance officers often save companies from catastrophe.<\/p>\n Political<\/u><\/strong>. Good compliance officers recognize allies wherever they may be and are not afraid to seek their assistance. Compliance and ethics professionals regularly seek advice about how to handle severe internal conflicts that cannot be resolved through escalation. Often the best solution is to resort to political skills. Political skills in this context does not mean the skills of a politician who deftly avoids or exploits controversy in the interest of getting elected. Nor does it mean self-promotion. In this context, political skills include influencing, leading, and earning trust of people over whom one has no formal authority or power\u2014a situation most compliance professionals find themselves in at one time or another.<\/p>\n Steal Shamelessly<\/u><\/strong>. Good compliance officers don\u2019t much care where good ideas arise\u2014and they give credit where due (of course paying appropriate licensing fees where required and otherwise respecting intellectual property rights). But in the spirit of responsible use of resources, they use what they\u2019ve got and what they can get. This is politely known as deploying best practices. Great compliance officers utilize their organization\u2019s talent\u2014legal specialists, business managers, engineers, auditors, etc. If the Human Resources or Finance Departments have developed great training methods on conflicts of interest, the good compliance officer will deploy such training into the general compliance training.<\/p>\n Obsessed About Money<\/u><\/strong>. Contrary to the views of some business managers, good compliance officers believe their mission is quite the same as everyone else\u2019s\u2014to protect the assets of their organization. Consider how much compliance and ethics efforts are focused on fraud, waste, and abuse. A good compliance officer insists on considering the financial consequences of every business decision. Not just short-term monetary costs, but medium- and long-term costs\u2014including reputational costs, relationship costs, environmental costs, impact costs on the community\u2014and the limitations that one decision can place on the flexibility to make other decisions. And of course, in the case of very bad decisions, compliance officers must weigh the direct costs of fines, penalties, possible imprisonment, as well as the legal, accounting, and other expert fees associated with addressing\/remediating such bad decisions.<\/p>\n Never Satisfied<\/u><\/strong>. Sometimes businesspeople want there to be a finish line for compliance. But the good compliance officer is instead focused on continued improvement and constantly asks questions like: How can we do it better? Is our risk profile and prioritization still accurate? Can our program succeed despite flawed individuals at any level of the organization? What are we missing? Has the world changed from 5 years ago? This is all part of some fundamental elements of an effective compliance program\u2014ongoing monitoring, auditing, and benchmarking.<\/p>\n Unpleasant though some of the above traits may seem, someone needs to use them. Hopefully that someone is within your organization. If not, these traits might be imposed upon you from the outside.<\/p>\n Michael Donnella is a Practice Professor of Law and the Director of Temple\u2019s Center for Compliance and Ethics.<\/em><\/p>\n","protected":false},"excerpt":{"rendered":" Temple Law\u2019s Center for Compliance and Ethics\u2019 Michael Donnella considers how unfavorable personality traits can be extremely helpful when properly leveraged by compliance officers.<\/p>\n","protected":false},"author":33,"featured_media":3303,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[13,52,22,8],"tags":[2441,1816,426,106,2442,1796,2443,2444,2147,1477],"coauthors":[2314],"class_list":["post-3301","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-business-law-practice","category-compliance","category-corporate-responsibility","category-faculty-authored","tag-attentiveness","tag-best-practices","tag-communications","tag-compliance","tag-conflicts","tag-management","tag-personality","tag-politics","tag-prioritization","tag-professionalism","masonry-post","generate-columns","tablet-grid-50","mobile-grid-100","grid-parent","grid-33"],"yoast_head":"\n