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The Character Imperative in Leadership: A Lesson for Compliance Professionals

When discussing leadership transitions at troubled organizations, one recurring theme is often overlooked: character’s pivotal role in shaping culture and outcomes. In an MIT Sloan Management Review article entitled “Make Character Count in Hiring and Promoting,” Mary Crossan posited, “Most managers focus on competencies when evaluating candidates—but it’s a character that will transform the DNA of the organization.”

The recent challenges faced by Boeing serve as a cautionary tale for compliance professionals worldwide. Despite their technical prowess and storied history, Boeing’s leadership failures, rooted in compromised decision-making and a lack of character-driven judgment, led to catastrophic consequences for safety, public trust, and, ultimately, their bottom line.

The leadership debate at Boeing has focused narrowly on whether the next CEO should be an engineer or an accountant, emphasizing competencies over character. This approach underscores a persistent failure across industries to recognize that strong character-based judgment is a cornerstone of ethical leadership and compliance success.

This offers a critical lesson for compliance professionals: character matters as much as, if not more than, competence. The organizational culture we build reflects the character of the individuals we hire, promote, and retain. Compliance leaders must champion character as a vital element in talent development and how to embed this principle into their practices.

Competence vs. Character: Understanding the Difference 

Competence concerns what someone can do, their technical skills, knowledge, and experience. It varies by organization, role, and level within the hierarchy. In contrast, the character is about who someone is. It’s universal and intrinsic, shaped over a lifetime, and critical to ethical decision-making.

Research shows that character comprises 11 interconnected dimensions, each manifesting in observable behaviors. These dimensions include courage, humility, temperance, accountability, and judgment. Importantly, character isn’t static; it’s a habit that can be developed and refined over time.

When organizations equate character with a narrow set of qualities, such as drive and accountability, they risk embedding toxicity and poor judgment into their culture. For example, a leader with unrestrained courage may veer into reckless decision-making without the tempering force of humility. Such imbalances ripple through the organization, driving disengagement and turnover among those with stronger, more balanced character.

This interplay between character and culture is a leverage point for compliance professionals. We can foster ethical cultures prioritizing accountability, transparency, and trust by elevating character assessments to the same level as competence evaluations. 

Character Interviews: A Tool for Compliance Leaders

Traditional interviews focus on competencies through structured questions and rubrics. Character interviews, however, require a more nuanced approach. They are conversational and personalized, designed to explore a candidate’s life story and reveal their character dimensions.

Here are key considerations for conducting effective character interviews:

  1. Prepare by Developing Your Own Character. To assess the character of others, interviewers must first reflect on their biases and imbalances. For instance, understanding the dimension of justice requires recognizing how systemic privileges and inequities shape perceptions of fairness.
  2. Engage in Genuine Conversations. A character interview should feel less like a formal assessment and more like exploring the candidate’s experiences, motivations, and values. This approach uncovers the layers of their character organically.
  3. Probing Questions and Observational Insights. Start with broad, open-ended questions and follow the threads of the candidate’s responses. For example, if candidates emphasize their innovative drive, explore how they’ve balanced it with temperance or collaboration.
  4. Cluster Dimensions to Identify Strengths and Weaknesses .Character dimensions are interconnected and should be evaluated holistically. A candidate with strong accountability and courage but weak temperance might struggle to balance ambition with thoughtful decision-making.
  5. Assess the Interviewer’s Character. Character interviews reveal the interviewee’s strengths and weaknesses as well as the interviewer’s. Candidates often assess organizations based on the character of those conducting the interviews.

Character in Promotions and Talent Development

Promotions signal what qualities an organization values most. When those decisions prioritize competence over character, they risk elevating individuals whose imbalances could undermine ethical culture.

One effective approach is integrating character assessments into 360-degree reviews for promotion candidates. For example, an organization identified a highly competent leader whose humility and collaboration needed development. By assigning him to an unfamiliar overseas role, they created an environment where he had to rely on others and build relationships, strengthening his weaker character dimensions.

Compliance professionals can advocate for similar strategies, ensuring that promotions are about past performance and readiness for ethical leadership.

Building Character-Based Cultures in Compliance

Embedding character into hiring and promotion decisions isn’t just about individual roles; it’s about shaping organizational DNA. Here is how compliance teams can lead this transformation:

  1. Educate on the Importance of Character. Host workshops or training sessions on the 11 dimensions of character and their relevance to compliance and ethical decision-making.
  2. Develop Character Assessment Tools. Create structured yet flexible frameworks for evaluating character in interviews, performance reviews, and succession planning.
  3. Provide Feedback for Development. Constructive feedback helps individuals recognize and address character imbalances. Compliance leaders can normalize character development as an ongoing process.
  4. Model Character-Driven Leadership. Compliance teams should exemplify the values they seek in others, demonstrating integrity, transparency, and humility in their interactions and decision-making.

The Compliance Professional’s Role

Character-driven leadership is essential to navigating today’s complex ethical landscape. For compliance professionals, this means advocating for systems that value character alongside competence. It means challenging the status quo in talent management and championing leaders who embody integrity, humility, and balanced judgment.

Boeing’s leadership failures are a stark reminder of what happens when a character is sidelined. By prioritizing character in our organizations, we can mitigate risk and build cultures that inspire trust, accountability, and long-term success.

Your corporate compliance function’s future and your entire organization depend on it.

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2 Gurus Talk Compliance

2 Gurus Talk Compliance: Episode 34 – The Whistleblower Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode!

In this episode, Kristy and Tom delve into an array of timely topics. They discuss how and why HR is now seen as the ‘Department of Misery.

The duo takes a deep dive into the new DOJ Whistleblower Incentive Program. They also discuss the huge Meta settlement with the state of Texas, SFO prosecutions and corporate felony convictions. Of course, Florida man makes an appearance with another great tale. Tune in for a comprehensive mix of compliance nuts-and-bolts insights and current events.

Stories Include:

  • For Big Companies, Felony Convictions Are a Mere Footnote (WSJ)
  • HR: the Department of Misery?  (NYT)
  • Can a corporate vote overturn a court decision? (FT)
  • Income inequality and corruption. (The Economic Times)
  •  The DOJ announces a whistleblower incentive program. (WSJ)
  • Glencore trader criminally charged by SFO for bribery. (FT)
  • OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes (Volkov) – VolkovLaw
  • Meta agrees to $1.4 billion settlement in Texas biometric data lawsuit over Facebook images (CNBC)
  • Will AI kill meaningless jobs? (NYT)
  • ‘Before He Cheats:’ Florida woman accused of keying ‘CHEATER’ on man’s car (Click Orlando)

 Resources:

Kristy Grant-Hart on LinkedIn

Spark Consulting

Prove Your Worth

Tom

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Compliance Tip of the Day

Compliance Tip of the Day: 10 Questions Compliance Should Pose to HR

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we consider the 10 key questions compliance should pose to HR.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.

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Daily Compliance News

Daily Compliance News: August 5, 2024 – The Dept. of Misery Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee and listen to the Daily Compliance News. All from the Compliance Podcast Network.

Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

In today’s edition of Daily Compliance News:

  • HR: the Department of Misery? (NYT)
  • Income inequality and corruption .  (The Economic Times)
  • Can a corporate vote overturn a court decision? (FT)
  • DOJ announces whistleblower incentive program. (WSJ)

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: Compliance Gap Analysis for HR

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

Today we discuss how compliance can perform a gap analysis for HR.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

To check out The Compliance Handbook, 5th edition, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: HR Touchpoints for Compliance

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In today’s episode, we begin an exploration of how HR can assist in the operationalization of compliance through its number of employee touchpoints.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Compliance Tip of the Day

Compliance Tip of the Day: Internal Reporting and Layoffs

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law. Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we look at the always tricky issue of internal reporting, whistleblowers during layoffs.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Sunday Book Review

Sunday Book Review: January 21, 2024 The Books on HR Edition

In the Sunday Book Review, I consider books that would interest the compliance professional, the business executive, or anyone who might be curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest me. Over the month of January, we will review some of the best books reported by People Managing People in various categories. In today’s edition of the Sunday Book Review, we look at four books on HR you should read in 2024.

  • The Essential HR Handbook by Sharon Armstrong and Barbara Mitchell
  • Irresistible: The 7 Secrets of the World’s Most Enduring, Employee-Focused Organizations by Josh Bersin
  • Built for People: Transform Your Employee Experience by Jessica Swaan
  • Remote Not Distant by Gastavo Ruzzetti

Resource:

28 Best HR Books You Should Read in 2024

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.

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Daily Compliance News

Daily Compliance News: October 16, 2023 – The HR into the Modern Era Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Stories we are following in today’s edition:

  • Bringing HR into the modern era.  (WSJ)
  • Geopolitical volitivity. (FT)
  • Doctor charged with taking kickbacks from Insys settles. (Reuters)
  • Myanmar steps up anti-corruption crackdown. (NikkeiAsia)
Categories
Blog

Employment Separation: A Compliance Centric Approach

Welcome back to our blog series on building a more effective compliance program! In today’s episode, we dive into the challenges compliance professionals face when dealing with employment separation, layoffs, and managing whistleblower allegations. We’ll explore practical advice and data-driven insights to help you navigate these complex situations. So, let’s get started! While compliance practitioners may be thinking about these issues, HR professionals may need to be fully aware of their significance. By working together, compliance and HR can ensure that exit interviews are conducted with the necessary guidance and attention to compliance-related matters.

One key aspect is the importance of collaboration between the compliance, legal, and HR departments. By working together, you can identify high-risk employees who may be subject to layoffs. This proactive approach allows you to plan and ensure that all compliance requirements are met during the separation process. To further strengthen your compliance program, consider involving a compliance professional in the exit interview process. This individual can ask detailed questions and emphasize the importance of compliance and ethical conduct. By doing so, you create an opportunity to address any potential concerns or ethical issues before they escalate.

Exit interviews serve as a goldmine of information for improving your compliance program. By asking detailed questions about what works, what doesn’t work, and what the employee would like to see, you gain valuable insights into the organization’s strengths and weaknesses. This unfiltered environment allows departing employees to freely share their thoughts, providing a unique perspective that may not have been voiced during their tenure.

During exit interviews, it is essential to ask probing and insightful questions specifically related to compliance. This helps uncover any compliance issues that may have contributed to the employee’s departure and identifies areas for improvement. By understanding the employee’s role, the structure of their business unit, and their supervisors, you can tailor questions to gather the most relevant and actionable information.

When planning layoffs, it’s crucial to consider the impact on hotlines, whistleblower reports, and retaliation claims. Data mining the hotline for employees who have reported violations and promptly investigating those allegations is essential. By demonstrating that layoffs are part of a consistent and fairly applied employee separation program, you can mitigate the risk of retaliation claims.

Treating departing employees with dignity and respect is not only the right thing to do but also essential for maintaining a positive compliance culture. Rushing employees out the door without consideration can increase the risk of retaliation claims or whistleblowing. Instead, take the time to listen to their concerns, answer their questions, and provide information on employment separation issues and state unemployment law. Offering assistance in finding future employment can also help ease the transition.

Treating departing employees with dignity can also turn them into powerful advocates for your organization. In today’s highly mobilized social media world, compliance ambassadors play a crucial role in defending your organization’s reputation and recommending it to potential employees. These ambassadors can also help communicate with stakeholders, third parties, customers, local communities, board of directors, and shareholders, reinforcing your commitment to compliance.

Compliance ambassadors can be a powerful tool when regulators come knocking. Their firsthand experiences and insights can provide additional resources and support in navigating regulatory challenges. By leveraging the knowledge gained from exit interviews, organizations can better prepare for compliance audits and demonstrate a proactive approach to regulatory compliance.

Separation documents must meet Securities and Exchange Commission (SEC) requirements regarding disclosures on whistleblowing and reporting to authorities. Failure to include language specifying that employees can go to authorities has resulted in major fines against US corporations. Ensure that your separation documents comply with these SEC requirements to protect both the company and the departing employee.

In conclusion, a comprehensive and respectful approach to employment separation and managing whistleblower allegations is crucial for maintaining an effective compliance program. By collaborating with HR, involving compliance professionals in exit interviews, addressing whistleblower reports and retaliation claims, valuing departing employees, and ensuring SEC-compliant separation documents, you can mitigate risks and foster a culture of compliance within your organization. Please plan for this eventuality to avoid the ex-employee being uncooperative with the company or government. By considering the potential value of a laid-off employee, you can better prepare for these situations.