I have long advocated that your ethics and compliance program should be embedded directly into your hiring process. However, let me be even more succinct: compliance begins with the hiring process. A recent article in the Sloan Management Review, by William Reed, entitled “Ten Expert Tips for Smarter Hiring,” reviewed the hiring process and noted that “Each hiring decision shapes not only who joins your team but also how your company defines itself .” This means that every employee you bring on shapes not just the culture but also the risk profile of your organization. The flip side is that a single poor hiring choice can have a lasting impact on a business for years, while a strong hire can reinforce integrity and resilience.
For compliance professionals, the hiring process is more than a human resources function. It is a frontline defense against misconduct, reputational damage, and regulatory scrutiny. This makes the “Ten Expert Tips for Smarter Hiring” directly relevant for us. I have adapted this article through a compliance lens to determine lessons we can apply to building a workforce that supports ethics, integrity, and accountability.
1. Ask the Right Questions: Digging Past the Facade
Candidates often arrive at interviews with polished, even AI-generated, answers. The key is not just asking what they have done, but probing how and why they did it. Questions designed to elicit authentic responses, what Harris calls “bank-shot” questions, reveal traits like self-awareness, accountability, and judgment. In compliance-sensitive roles such as procurement, finance, or third-party management, probing questions can help determine whether a candidate dares to speak up, navigate ethical dilemmas, and handle pressure effectively. Hiring managers should coordinate with compliance to build integrity-related questions into interviews.
2. Probe for Substance, Not Scripts
It is not enough for candidates to recite processes. Follow-up questions should push them to explain reasoning, trade-offs, and lessons learned. This exposes whether the candidate has merely memorized best practices or internalized critical thinking. The DOJ consistently emphasizes the importance of judgment and decision-making. This is a key theme of the 2024 Evaluation of Corporate Compliance Programs (2024 ECCP). Compliance officers can coach hiring teams to listen for signs of genuine ethical reasoning rather than canned responses.
3. Character Over Competence
Competence can be trained; character is more complex to teach. Research cited in the article emphasizes that while technical skills vary, core attributes such as honesty, resilience, and fairness are universal and should be given significant weight in hiring decisions. Compliance programs thrive in cultures of integrity. Hiring for character builds the foundation for a speak-up culture, ethical decision-making, and long-term trust. Compliance should partner with HR to design behavioral interview questions that test for integrity and moral alignment.
4. Highlight Meaningful Work
Top candidates want more than compensation; they want purpose. Cues from the recruiting process, as well as stories of meaningful work and culture, affect not just acceptance decisions but also long-term engagement. Compliance professionals can play a role in branding the organization as a place where doing the right thing is valued. When candidates see integrity celebrated, it strengthens your ethical brand and attracts talent that aligns with your compliance values.
5. Employer Branding as a Compliance Asset
Strong employer branding is not simply about market competitiveness. It communicates the company’s identity and priorities. A well-articulated employer brand can establish expectations for ethical conduct and compliance from the outset. Compliance messaging should be embedded in employer branding. For example, highlight your whistleblower program as a sign of transparency and fairness. Utilize recruitment materials to convey that ethical leadership is integral to the company’s culture.
6. Autonomy and Accountability
Flatter hierarchies and broader spans of control mean employees must self-manage more. The right employees thrive in autonomy, while others struggle to do so. With increased autonomy comes increased risk. Compliance should ensure that hiring processes screen for accountability and conscientiousness. Self-directed employees must be able to manage risks without constant oversight.
7. Don’t Overlook Internal Talent
Internal lateral moves can unlock untapped potential. They often produce better long-term outcomes because employees already understand the company’s values and systems. Promoting internal talent not only saves costs but also rewards employees who have demonstrated a commitment to compliance with company policies and culture. It signals that integrity and alignment with values are valued, thereby strengthening the culture.
8. Beware Over-Reliance on Vendor Tools
Pre-packaged talent management software may simplify hiring, but it risks overlooking the nuances of your organizational needs. Just as with third-party risk, outsourcing too much of hiring to generic tools can create blind spots. Compliance officers should advocate for custom criteria that reflect ethical considerations, industry-specific risks, and regulatory obligations.
9. Skills-Based Hiring Requires Culture Change
Skills-based hiring is valuable, but it is not a quick fix. It requires cultural change and consistency across hiring, promotion, and retention practices. The same applies to compliance. Hiring for skills like ethical reasoning, critical thinking, and cultural competence must be reinforced through training, promotion decisions, and leadership modeling. Otherwise, skills-based hiring risks being performative.
10. Deploy Your Best Interviewers
Data shows that some interviewers are consistently better at identifying strong hires. Yet few organizations systematically identify and deploy these interviewers. Compliance professionals should advocate for training interviewers to recognize the red flags of unethical behavior. Identifying your “compliance-savvy interviewers” and deploying them in critical hiring processes strengthens your ability to hire ethically aligned candidates.
Final Thoughts
Hiring is not just about filling positions; it is about shaping culture, building resilience, and protecting the enterprise. For compliance professionals, more innovative hiring means embedding compliance into the very first step of the employee lifecycle.
Harris tips provide a roadmap: ask the right questions, probe for substance, hire for character, highlight meaningful work, strengthen employer branding, embrace autonomy responsibly, value internal talent, customize tools, make cultural shifts for skills-based hiring, and deploy your best interviewers. When compliance is part of the hiring process, you don’t simply acquire talent; you utilize the entire process to help build a culture of integrity. That is the ultimate compliance win.
