In this episode I visit with Feldman on what is the role of a CCO in strengthening the ethical culture of an organization. We began by considering that there are multiple levels and roles for those within and outside of the corporate compliance function within an organization. They include the CCO, a compliance practitioner and the compliance function itself. I asked Feldman how he sees the role of the corporate compliance function itself in strengthening the ethical culture of an organization? Feldman said it all begins with the response to a simple question, “who is responsible for culture in an organization?”
It is important for the CCO to be proactive in the role of shaping ethical culture, separate and apart from the CCO role in investigations, root cause analysis or ongoing monitoring. The CCO should work to eliminate barriers to aid in driving business success rather than being Dr. No from the Land of No. The CCO can work to coordinate all of the activities relating to building culture in an organization. Feldman provided a couple of examples.
The first was in the area of hiring and recruiting. Obviously, the nuts and bolts of this process is run through HR but the CCO can create a culture where the organization would only hire the right type of persons as employees. These hires would have an attitude and core values that are consistent with your company. A CCO can work to make sure that they understand the organization’s position with regard to fraud and other misconduct and this is incorporated into the interview process. Once a new employee is hired, the onboarding and training begins. Feldman noted that while HR certainly has a leadership role in those areas a CCO or corporate compliance function should also maintain a lead role to make sure the new employees understand their responsibilities in these critical areas. Further, Feldman believes, “it is a serious lapse” if the compliance function does not make clear that the company is quite serious about its Code of Conduct, that employees follow it and not violate it going forward.
This task is much more difficult without the leadership and the support of the Board. Feldman considers the role of the Board “is to provide leadership.” This is complimentary to the role of the CCO to ensure that the Board is “currently informed about the ground truth of the ethical culture and decision making of the company”. He believes one of the key areas has to do with warning signs, what are the warning signs of an unethical culture. This means it really is up to the compliance professional in the organization to have a good understanding of what is going on in the company and communicate any warning signs up to the CCO, CEO and the Board.
These warning signs can be a wide variety of behaviors and actions. Feldman said, “things like disrespectful attitudes, favoritism or nepotism in promotions or bonuses, low employee morale, lack of teamwork, a large number of anonymous whistleblower complaints which could reflect a fear of speaking up, employees who report that they were uncomfortable talking to their supervisors and are afraid of retaliation.” These are the kinds of things that a CCO needs to be on top of and communicate both the condition and recommended solutions to the CEO and Board.
Day: June 16, 2020
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Ryan Rabalais, currently an Ethics and Compliance Officer at Bechtel Oil, Gas & Chemicals. Rabalais has been Vice President and CCO at both Rowan Companies and Paragon Offshore.
Ryan Rabalais has over two decades of legal and compliance experience in the oil and gas sector, including being a Vice President & Chief Compliance Officer for two different companies with global operations. Ryan has a history of providing practical solutions to the business and managing overall corporate and regulatory compliance programs. His compliance experience includes a particular focus on anti-corruption, sanctions, trade controls and US anti-boycott, with reporting responsibilities to senior management and the Board of Directors of large, publicly traded companies.
In this Episode 3, Ryan relates some of the skill sets he has used in his journey to the CCO chair and while he has been in that position. They include being what Rabalais calls “Compliance wise” that is knowing the nuts and bolts of compliance and compliance programs so that you are a subject matter expert. You should also under how to do compliance; that is, how to design, create and implement a best practices compliance program. You should be able to communicate up and down the chain (here he brings the wisdom of a Marine. Finally, he ends with some thoughts on worldliness.
On this special bonus episode of The Ethics Experts, we speak with Lassaad Fridhi about how vendors are now in his day-to-day business, and why it’s so important to trust that you have the best ones working with you.
Check out more episodes, and don’t forget to subscribe on your favorite podcast platform!
Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. In this episode, I am joined by Scott Price. Scott has provided clients with security, assurance, and compliance solutions for nearly 20 years. In this time, he has completed over 2,000 SAS 70/SOC audits and has supported many Global 1000, Fortune 500, and regional companies. In 2009, Scott started A-LIGN to provide partnership to firms around the globe by solving their security and compliance problems. In 2016, Scott was selected to Accounting Today’s Managing Partner Elite, highlighting the leaders of accounting firms who stand out from their peers due to their ability to guide their firms through innovation, development of strong culture, and continued focus on growth.
In this episode, we consider some of the challenges for compliance professionals in the current environment around how Coronavirus is impacting the security and compliance industry; what are the benefits of conducting a remote audit; and what will the compliance landscape look like 6-9 months from now for cyber-risk and cyber-security? We conclude with a look at what might be the “new normal” look like for both clients and compliance firms?
For more information on A-LIGN, check out their website here.
Imagine you are in your BED and just don’t want to get out. You might feel a little fear, depression or shame. You want to pull up the covers and stay exactly where you are, but it’s time to flip off the covers, jump in your canoe and start paddling with your OAR and go from playing the role of a victim to becoming the victor.
I’m joined by my dear friend Marty Stanley on this #jammingwithjason #internalauditpodcast to discuss her “Get Out of B.E.D.” model. A simple model you can remember and use to get you out of blame, excuses, denial / drama and instead take ownership, accountability, and responsibility for you actions. Get out a pen and paper so you can draw the model and we talk through each part.
This simple model has helped me for years and I am so excited to share Marty and her model with each of you.
To get a copy of the Get Out of B.E.D. model and connect with Marty, visit her website: http://alteringoutcomes.com/ email her at: martystanley@alteringoutcomes.com, or connect with her on LinkedIn: https://www.linkedin.com/in/martystanley/
Dan Wager heads Financial Crime Compliance Strategies at LexisNexis Risk Solutions. His global team focuses on identifying market opportunities, merger acquisition opportunities, regulatory developments, and product development in the areas of anti-bribery, anti-corruption, money laundering, sanctions screening, and sanctions enforcement. He joins Tom Fox on this week’s show to chat about the key findings of LexisNexis’ report, The True Cost of Financial Crimes, and its implications for compliance professionals.
Understanding Financial Crime
“One of the things I’m trying to do,” Tom tells Dan, “is bring people like yourself on the podcast to really help the anti-corruption compliance specialist who’s in the commercial corporation understand financial crimes.” Dan comments that LexisNexis has been doing this report for five years but at the regional level. This report, by contrast, is a global roll-up overview, where they are bringing the regional studies together into a global view, to see the true cost as well as challenges and trends facing the industry.
Key Insights
Dan and Tom discuss the key findings from the report, including:
- The true cost of compliance globally is in excess of $180 billion a year.
- Each region has its own compliance risks and issues.
- Non-bank payment providers pose various compliance challenges, in particular for clearing banks.
- The increasing compliance burden has an adverse impact on attracting and retaining talent.
- The proper use of the right technologies can assist in offsetting costs and making better compliance decisions.
A Layered Approach to Compliance
Using a layered approach helps a compliance professional think through the risk management of their compliance program, recognizing that implementing financial crime compliance initiatives can provide broader benefits to their business. Dan explains that the layered approach to compliance starts at the front gate, and it involves using technology to determine whether the person or proposed action poses a compliance risk. “The layered approach means before you spend something on someone or give money to someone or buy something from someone you should have vetted them,” he points out. Tom asks about page 45 of the report. Dan says that it’s about using the right technology for your business’ needs. That is what will reduce labor cost, he points out. “It doesn’t mean that you can hire cheaper labor. It means you have fewer people to accomplish the same compliance because you’re automating and accomplishing through technology much of the rote work.”
Resources
LexisNexis Risk Solutions
Study: The True Cost of Financial Crimes
In today’s edition of Daily Compliance News:
- Six eBay employees indicted for horrific campaign of cyber-stalking. (Boston Globe)
- Al Jaffe retires from Mad Magazine? (NYT)
- GOP scuttles yet another piece of privacy legislation. (WSJ)
- LGBT rights upheld in the workplace. (WSJ)
