Day: January 21, 2022

Over the past week, I have been considering Joel Coen’s The Tragedy of Macbeth currently appearing on Apple TV. I have been reviewing the film and exploring my love of all things Shakespeare. Today, to end this series I want to talk about the remarkable performance by Kathryn Hunter as not one but all three of the weird sisters (3 witches) of the play.
In a New Yorker article, entitled “Weird Sisters? Make that the Twisted Sisters”, Henry Alford interviewed the actor and explored her preparation for the role. First a word about her performance which was nothing short of mesmerizing. Hunter contorted her body in the very first sisters’ scene where she prophesizes that Macbeth will become the Thane of Cawdor. It was basically acting with her body in addition to the dialogue. As the camera closes in on her you see not only her contortions but her dramatic voice. Of this scene, Alford wrote, “Hunter’s first scene in the movie has her squatting in the sand (no panty hose), where she alternately squawks, clutches a sailor’s severed thumb in her gnarled toes, and twists her right arm all the way behind her head. Imagine a litigious raven who has done a lot of yoga.”
Equally impressive was Hunter’s preparation for the role, which only lasted a slim few minutes in the entire movie. Alford wrote, “For her “weird sisters” research, Hunter studied people with multiple-personality disorder, and also crows, which are symbols of divination. She also consulted a modern-day witch. “I asked her to give me a simple spell to keep the company safe,” Hunter said. “Denzel told me he believes in the power of prophecy and the power of blessings, so, before going on set, I would do a ritual to keep him and the company safe.””
Finally, in the film, “Hunter also plays the Old Man outside Macbeth’s castle, which suggests that the witches have shape-shifted into an old codger. It’s the Old Man who, referencing first the darkness of the sky and then Duncan’s murder, says, “ ’Tis unnatural / Even like the deed that’s done.” Hunter was quoted by Alford, “It’s amazing that Shakespeare was so concerned with nature. He’s saying, When man is out of kilter, as it were, it’s reflected in nature. How prescient is that?”
I thought about Hunter’s performance and her innovative use of her body to communicate so well in the movie for my final exploration of transforming your compliance program. In a MIT Sloan Review article, entitled “Use Networks to Drive Culture Change”, authors Peter Gray, Rob Cross and Michael Arena posit that culture is difficult to change, “in part because it reflects people’s values — their deeply held beliefs about what is good, desirable, and appropriate. Relationships can complicate matters further. When colleagues are embedded in informal networks with others who share and reinforce their values, they often become entrenched rather than open to new attitudes and behaviors. But it doesn’t have to be like that. Those same networks can also help leaders identify and overcome obstacles to cultural change and discover unexpected allies.” Their approach has some innovations which every Chief Compliance Officer (CCO) should study to help in the culture transformation of your organization.
Deputy Attorney General Lisa Monaco, in her October speech, renewed the Department of Justice’s (DOJ) emphasis on corporate culture stating, “Now, I recognize the resources and the effort it takes to manage a large organization and to put in place the right culture. The Department of Justice has over 115,000 employees across dozens of countries and an operating budget equivalent to that of a Fortune 100 company. So, I know what it means to manage and be accountable for what happens in a complex organization. But corporate culture matters. A corporate culture that fails to hold individuals accountable, or fails to invest in compliance — or worse, that thumbs its nose at compliance — leads to bad results.” Clearly, she is signally a more focused DOJ interest in culture. This means you need to be ready to not only transform your culture but also document the transformation.
There are five steps which I have adapted for the compliance professional.

1. Unearth the Subcultures. It turns out that culture is created not holistically but by corporate subgroups, which have their own cultures and cultural leaders. CCOs often think about the culture of their area of the organization and take action at that level, which across an organization culture is only partially influenced by holistic structures; it is also shaped and reinforced by subnetworks of employees who may spread across many different units. CCOs need to “see the diversity of values that exist in different cultural subnetworks can take much more precise action to support or change these subcultures.”
2. Find Your Real Cultural Leaders. Here the key for compliance is that “Informal influencers deep inside the organization are critical — but often hidden — enablers of change. Enlisting their help is far more efficient than taking a top-down approach.” As the CCO you need to identify these real subunit leaders, get their buy in and then enlist them to lead your cultural transformation.
3. Shine a Light on Hidden Tensions. There are always disagreements throughout an organization which can kill cultural changes, usually through the proverbial death by a thousand cuts. Analyzing network and cultural data can bring these tensions to light so leaders can manage them. A key one can be what the authors called, “toxic misalignments, where cultural influencers with very different values interacted in negative and dysfunctional ways”. Here the role of the CCO is to be a facilitator, to “appeal to a higher shared value can resolve a deadlock, but only after uncovering value misalignment and discovering who sits on which side.”
4. Evoke Positive Emotions. I hope that you as a CCO have a positive outlook. Most CCOs I know are eternal optimists, even those who come from the General Counsel’s office. While a standard tactic to lead cultural change is rationality; i.e., explain and educate using “compelling logic, in hopes of persuading them to commit to new ways of working” the authors found their “research shows that culture spreads most effectively through network connections that have an emotional aspect.” As a CCO you should bring an energy and excitement level and then start “training first-level supervisors to become more skilled as “energizers.” They learned how to engage people in realistic possibilities that captured their imaginations and hearts, for example, and how to help others see how their efforts contributed to an ambitious plan. Nine months later, new data revealed far greater adoption of the new cultural values among individual contributors.”
5. Give Adoption the Time It Needs. The authors found that the time to change culture can vary and “leaders may see slow or uneven adoption as new cultural ideas’ failure to spread, when in fact it may be a function of how tacit or complex the values are. And while networks play an important role in speed of adoption, faster isn’t always better.” The bottom line for the CCO is to give it time. But use the tools you have available to assess, monitor and improve your culture transformation program. Mid-course corrections are allowed. The authors concluded, “Combining network analysis with assessments of organizational culture provides leaders with a rich understanding of how new values take root.” This can provide to a CCO a more focused even “local” view of culture, where desired behaviors are communicated, modeled, observed, and adopted on the ground, not broadcast from on high. This in turn allows a CCO to drive cultural transformation in more targeted ways.

I hope you have enjoyed this short series drawing inspiration from Macbeth to discuss transformation of your compliance function as much as I have enjoyed watching the movie, researching the topic and writing about it.