Day: February 10, 2022

As usual during the Oscar season, Richard Lummis, my co-host on the podcast series 12 O’Clock High, a podcast on business leadership, and I do a special 4-part podcast series on Best Picture winning Oscar movies. We mine them for leadership lessons for the compliance and business leader in the 2020’s. It is also a great way to watch some fabulous old movies or even some which are not so old. Some movies are very intuitive on leadership lessons. Movies like Patton, Lawrence of Arabia or The Bridge on the River Kwai are clearly about leadership as well as multiple other themes.
This Oscar season we have a lineup of Schindler’s List, Gladiator, A Man for All Seasons and Platoon. The series premiers on Thursday, February 10, and runs for four consecutive weeks. I hope you will check it out. It is great to sit down with a movie, that you may not have seen in years and watch it with an eye towards leadership lessons. Equally enjoyable is reading the commentary on the movie, both film critique and more business and leadership focused commentary.
Next week’s offering will be Gladiator and one of the leadership lessons I garnered from the movie is the need to not only design your compliance strategy but practice it. Practicing is not often talked about in compliance. There is plenty of ink and commentary on designing a compliance program but almost none on practicing it after you design, create and implement it into a best practices compliance program.
One person who does talk about practicing compliance is Jonathan Marks. In a blog post entitled Crisis Management – Lights, Camera, Action! he wrote, “Even the best-prepared organizations will experience a crisis—and there’s rarely a perfect response. The ability to avoid disaster and avoid mismanagement of the situation—will largely be determined by the effectiveness of the organization’s crisis prevention efforts, crisis response plan, proper training of the crisis team, and leadership to manage the crisis effectively.” What is the solution to this imbroglio? Marks answers, “Practice, practice, practice…regularly conduct disaster rehearsal exercises or crisis management simulations that are impactful and help reveal blind spots that can be remediated and ultimately prepare you and your team for not if, but when something ugly happens.”
But you do not have to wait for a crisis to practice. You can do it on a regular basis and on a variety of areas in your compliance program. An obvious place to practice is around your internal reporting system. Can an internationally based employee reach the hotline to report a claim? Have you ever tested that proposition? Does your hotline work in each country where you have employees? In the local language of the employees?
However, being able to pick up the phone and make a hotline compliant is only the starting point. Do you have a triage protocol? Have you tested it? If you are a Chief Compliance Officer (CCO) have you sat down with your compliance team and run through some examples of reports that might come in to see where your team would send them and what advice they would provide at that point? Now think about the cost of performing such a ‘practice’ session. That is right it would be zero dollars. Always remember as a CCO or compliance professional you are only limited by your imagination and in this case, you can imagine many scenarios and use that imagination to practice your compliance team.
What about practicing formal internal and external audits? To do so you can employ a practice  audit. In the practice audit, the team will go through the factors which will be reviewed in a formal audit at your organization. The practice audit is a mechanism by which a compliance team can go into a location or business unit and not only try to determine what might need remediation but, equally importantly, help the employees move towards greater compliance. The team members who perform these practice audits need not always be compliance personnel. This allows you to train as you practice. These practice audits help to uncover gaps that need closing before any of the regulatory mandated audits by external audit teams. Obviously, the entire experience can be a powerful training tool as well as a practice exercise.
In the movie Gladiator, the character Maximus survives several gladiatorial bouts in the Coliseum by practicing. While not often considered in compliance, think about practicing your compliance program to see if it works, determine what can be improved but also train as you are practicing. As I noted above, the cost be can very low even if you bring a seasoned compliance professional to lead the practice session.
Finally, I hope you will check out the podcast series Lummis and I have put together for this year’s Oscar season. We had a ton of fun re-watching the movies, researching the lessons and then recording the podcasts. I know you will both get a lot of leadership and ethical lessons out of these podcasts but also find them quite enjoyable. Happy Oscar Season.