In this episode, I consider the Adventure of the Red Circle and how it informs listening and communication in a best practices compliance program.

Shmoop found that in addition to the overall storytelling of Dr. Watson, “nearly every character in the Sherlock Holmes stories is a storyteller.” Storytelling is a crucial part of the entire detective fiction genre, and the Sherlock Holmes stories really explore this aspect. Each tale begins with a new case, which is always narrated by a participant, and ends with some sort of confession/explanation scene. While we are on this journey with Holmes and Watson, both they and we “encounter tons of different people and listen to their stories. In a way, the cases that Holmes and Watson solve are like giant umbrella stories composed of a dozens of smaller stories being told by a revolving door of characters.”
In the story The Adventure of the Red Circle, Holmes solves the immediate mystery in front of him, as told by the landlady of a boarding house. The first mystery is that a lodger has not been seen for over 10 days, always staying in his room and only communicating with oblique messages such as SOAP, MATCH, DAILY GAZZETTE printed on a torn piece of paper. But Holmes divines a greater mystery as it turns out the lodger is not a man but a woman whose life is under threat and her male traveling companion can only communicate with her through references to newspaper columns. Holmes stated to Watson, “Education never ends, Watson. It is a series of lessons with the greatest for the last. This is an instructive case. There is neither money nor credit in it, and yet one would wish to tidy it up. When dusk comes we should find ourselves one stage advanced in our investigation.”
This story illustrates a couple of key points for every CCO and compliance practitioner.

1. The first is listening. Not only is listening a key part of any leadership skill but listening will bring you a much better picture of your compliance program, its faults and successes. The reason is that its own employees are a company’s best source of information about what is going on in the company. It is a best practice for a company to listen to its own employees, particularly to help improve its processes and procedures. This type of listening extends to an internal reporting system as a company should provide a safe and secure route for employees to escalate their concerns. Of course, the Dodd-Frank Whistleblower provisions also give heed to the implementation of a hotline.
2. This second compliance point is communication. Just as education never ends for Holmes, it should never end for a compliance practitioner, your communications on compliance should never end either. Louis Sapirman calls this a 360-degree approach to communications.