In this episode of Everything Compliance Shout Outs and Rants we have the following.
Karen Woody shouts out to the French TV show Call My Agent, reminding us that by watching a French language show with subtitles you can see really funny TV and learn French.
Jay Rosen rants about Boston sportswriter Longtime Boston Globe columnist Dan Shaughnessy for not voting for Red Sox great David Ortiz for the Baseball Hall of Fame.
Tom Fox shouts out the Joel Coen movie Macbeth and starts Oscar buzz for Kathryn Hunter as Best Supporting Actress.
Matt Kelly laments about the story of Harmony Montgomery, now missing for over 2 years because no one would take her mother’s speaking up about her disappearance seriously.
Jonathan Armstrong shouts out to UK artist Tracy Emin who shames British PM BoJo by asking for removal of her art from No. 10. He ends with the plea BoJo Must Go!
Tag: Macbeth
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Macbeth and Culture Transformation
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.
- 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.”
- 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.
- 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.”
- 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.”
- 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.
Over the weekend I saw Joel Coen’s The Tragedy of Macbeth on Apple TV. To say it blew me away would be putting it mildly. I have been reviewing the film this week and exploring my love of all things Shakespeare in this week’s blog posts. Today, I want to consider Frances McDormand in her starring role as Lady Macbeth and how her experiences of life point to learning curves.
McDormand herself said that she was destined to play the role. Stephen Schaefer, writing in the Boston Herald, quoted her for the following, ““The first thing that got me hooked on being an actor the rest of my life was the sleepwalking scene from ‘The Tragedy,’” she said of Shakespeare’s guilt-ridden murderess Lady Macbeth, who can never wash the blood from her hands. “I did it when I was 14,” she said. “Then I’ve been pretty much practicing and rehearsing for it for 50 years. It had kind of a fated inevitability to it.””
While other versions of Macbeth, notably Roman Polanski’s 1972 version, used younger actors in the lead roles, here Director Coen focused on older versions of the Macbeths. Schaefer also focused on the experience of the actors, McDormand and Denzel Washington, playing the lead roles. Both actors understand about the drive to achieve the next success, which for Macbeth was to take over the Kingdom of Scotland. Schaefer also noted, “McDormand, 64, agreed. “You might think they don’t understand. But guess what? We understand because when we first talked about the film, Denzel and I (it was our own private conversation), both understood about each other: There’s always been a fight. We fought it as gracefully as possible. The fight’s never going to be over. “So we brought that to it. We still know how to fight. Maybe we were limping a little bit. Maybe it took us a little bit longer to get there, but the fight was still there.””
In a recent Harvard Business Review (HBR) article, entitled “Managing Your Organization as a Portfolio of Learning Curves”, author Whitney Johnson, posited, “As people develop competence in a new domain of expertise, they move along an S Curve: Growth is slow and effortful at the outset, or launch point. It then progresses rapidly as people acquire new skills in a stretch known as the sweet spot. At the peak is mastery, when work becomes easier but the curve flattens. Understanding where your employees are on this S Curve of Learning will help you coach them appropriately, craft thoughtful succession plans, and build a team with diverse but complementary strengths.” I use the article as a starting point for the Chief Compliance Officer (CCO) to use it to aid in developing a strong compliance bench at your organization.
The ‘S’ learning curve has three components; (1) launch point, (2) sweet spot and (3) mastery. It was originally developed by Everett M. Rogers, “to show how new ideas and technologies spread.” However, Johnson also saw it as “the trajectory that people move along as they develop competence in a new domain of expertise.” She calls it the “S Curve of Learning;” where growth is slow and effortful at the outset, which is the launch point. The initial phase is “followed by rapid upward progress as people acquire new skills and overcome setbacks: a stretch I think of as the sweet spot. At the peak is mastery—when work becomes easier, but the curve flattens because there is little left to learn. When that happens it’s time to jump to the bottom of a new S Curve, put in the effort, and experience the thrill of climbing again.”
Johnson applied this concept to three areas which are also important to the corporate compliance team; talent development, succession planning and building an “A Team’. Many have said that talent development, acquisition and retention will be one of the most critical corporate endeavors going into the 2020’s. This is even more true for the compliance function. Our discipline is at a cross-roads with many non-legal concepts becoming more important. Such skills as data analytics, behavioral psychology and others are replacing the need to be able to recite the text of the Foreign Corrupt Practices (FCPA). The S Curve in talent development gives CCOs and their compliance team members a “common language for discussions about personal growth and talent development—about people’s progress in their roles and their future with the organization. When one of your reports says, “I’m at the launch point,” you’ll know that person is struggling to gain traction. When someone says, “I’m in the sweet spot,” he or she has momentum and is feeling competent and confident. And when you hear an employee say, “I’m in mastery,” the message is clear—“I know I’m good at this, but I can’t keep doing it—I need a new challenge.””
Under succession planning, it is not enough to plan what is next for the organization or even your compliance team; you also need to consider what is next for the individual. Johnson wrote, “Doing this well involves anticipating which people might move on and when, identifying team members who might assume this role, and then thinking about those who could backfill that role.” In other words, you need think of it as a multi-dimensional chess game; not only thinking several moves ahead but also on X, Y and Z axes. Such an approach allows you to “see when the high-contribution sweet spot is about to yield to mastery, and shortly thereafter, boredom and stagnation. Keeping people who’ve reached the mastery stage in a role for too long carries risks. An employee can become complacent or a flight risk. And if, as an organization or team, most of your people are in the sweet spot, humming along, you may be courting the danger that your entire team could suddenly be in mastery, setting off a wave of departures. Counter these risks with succession planning for each individual.”
Now think about all of the above in building out your ‘A’ compliance team. Johnson advocates diversity in talent on the ‘S’ curve so that some team members are on the sweet spot and some in the others. She stated, “You want people who have a variety of aptitudes and ambitions, and you want a balanced portfolio of people at different stages of growth. People in mastery have deep experience, people at the launch point bring fresh perspectives, and those in the sweet spot have both the enthusiasm and competence to breathe life into a project. Although every team is different, many look like a bell curve, with most members in the sweet spot at any given time and a small percentage of people at the launch point and in mastery. When putting together a team, smart leaders make sure they have people on all major phases of the curve—what I call a matched team.”
Just as McDormand’s portrayal of Lady Macbeth is thought-provoking so is Johnson’s piece. If you are looking for a low-cost way to improve your compliance team, this approach gives you several ways to think through talent development, retention and advance.
Tomorrow, the sisters.
Over the weekend I saw Joel Coen’s The Tragedy of Macbeth on Apple TV. To say it blew me away would be putting it mildly. I have been reviewing the film this week and exploring my love of all things Shakespeare in this week’s blog posts. Today, I want to consider Denzel Washington in his starring role as Macbeth.
Jourdain Searles, writing in okayplayer.com, said, Washington’s “acting style has always been theatrical, and he’s an obvious choice for any role that requires the ability to monologue while still keeping the audience engaged. Washington is definitely up to the task, making a meal out of every scene. And yet, his motivations in the film feel murky. Due to his age and visible exhaustion, it seems like Washington’s Macbeth would rather retire than vie for the Scottish throne. When his wife Lady Macbeth (Frances McDormand) urges him to seize the throne, it comes off more of a burden than a shining opportunity. Having the couple be older is an inspired choice, transforming the characters from youthful schemers to weary elders making their final grasps at greatness.” I noted this world-weariness, as well as the issue of succession. I want to use those twin concepts to introduce today’s subject of your compliance team leadership.
In a recent Harvard Business Review (HBR) article, entitled “Reinventing Your Leadership Team”, authors Paul Leinwand , Mahadeva Matt Mani, and Blair Sheppard, all with PwC, posited that “in our increasingly complex world, what companies really need to do is build new forms of competitive advantage and transform themselves for the future. And that requires fundamental changes in their top leaders—not just in individuals’ capabilities but in the way they collectively steer the ship. Drawing on their research at 12 prominent global firms, the authors note the contradictory-seeming skills that leaders are expected to have—being both great visionaries and expert executors.” I use their article as a starting point for the Chief Compliance Officer (CCO) to put together a top-notch compliance leadership team.
As legally trained CCOs continue to become less relevant to a corporate compliance function and with the new-found compliance framework focused largely on digitizing and digital analysis, what companies and their employees need from compliance leadership is evolving. CCOs must be able to reimagine a compliance function’s place in the world and transform the organization to live up to a more ambitious purpose. That will mean fundamental change not only in CCOs themselves but also in how they collectively manage and lead a corporate compliance function.
Within the broader context of corporate leadership, the authors stated, “Consider, for example, how the skills that leaders need for success have evolved—and the degree to which many executives are seen to struggle with these new demands. A recent survey conducted by Strategy&, PwC’s global strategy consulting business, highlighted the importance of balancing certain characteristics that on the surface look paradoxical. We used to accept, for instance, that leaders could be either great visionaries or great operators. No longer. Companies now need their top people to perform both roles—to be strategic executors, in other words. They’re also expected to be tech-savvy humanists, high-integrity politicians, humble heroes, globally minded localists, and traditioned innovators. Not only did large majorities of the survey respondents agree on the importance of those roles, but they also voiced alarming concern about leaders’ lack of proficiency in them. Addressing a company’s leadership gaps, however, is not merely a matter of building individual executives’ skills. Although that’s certainly desirable, the need to improve collective leadership is urgent.” That certainly holds true for the compliance function.
The authors identified four key components for leadership change, which I have adapted for the corporate compliance function.
Identifying the leadership roles needed to transform compliance for the future. For compliance to remain relevant, it will need distinct capabilities that allows it to deliver on its purpose, along with leaders who can envision its new place in the world and mobilize it to get there. What positions does your CCO need on their team to make that happen? Obviously, the basic legal skills of reading and writing are now only the basics. There must be digital talent, innovation talent, behavioral psychology talent, as well as communications. Moreover, all these roles will need to work collaboratively not simply with each other but with a much wider variety of internal and external stakeholders than ever.
Assembling the right people. Having the right roles is not enough as once you have identified the roles your compliance function needs, “you next have to think about who will best fill them. Which individuals should you bring together so that you have the necessary talent and diversity…to generate new ideas, challenge traditional thinking, and collaborate on meaningful change?” You will need team members who can not only see around corners but also respond to the ever-changing compliance landscape of today’s business as usual, through continually recalibrating the risks your organization faces.
Focusing your leadership team on driving your compliance transformation. Obviously as CCO, you and your compliance team “will need to advance the company’s agenda—and that means spending energy and time on the big priorities for the future, not just responding to the demands of the organization today. What structures and mechanisms will help you lead the company to its new destination?” How can compliance initiatives work to increase business efficiencies, drive greater employee engagement and move the need on overall company profitable? It is not simply business efficiencies you must master as you must build trust in your organization to create a true ‘speak-up culture’ so you can reap the benefits of this increased efficiency.
Taking ownership of your team’s behavior. At first blush this would seem like a natural for compliance. Afterall, compliance is all about taking ownership and transparency. However, the authors’ focus is a bit different, “Creating ownership around the vision isn’t enough. You must also create a shared purpose: Why does your team exist? What big issues is it here to solve? When defining their areas of responsibility, your people should believe that leading the company through its transformation is their most important task and that success will depend on the collaboration of team members rather than on the sum of individual units’ performance.” In other words, build on the trust you created by giving the credit out so that all will be invested in your compliance transformations.
No major corporate transformation can be successfully achieved by the compliance team alone. There must be engagement, buy-in and not simply acceptance but an embracing by the employees. The authors conclude that you should “Surround yourself with talented people who can balance seemingly paradoxical leadership behaviors and challenge one another to collectively accomplish big things. Most importantly, make sure your leadership team truly leads—setting aside the time and energy to define a bold agenda and launch the ambitious initiatives that your future relies on. Failing to do that will be a costly mistake. Succeed and you will have a powerful team that can position your firm to thrive in an increasingly complex world.”
Tomorrow, Frances McDormand and Lady Macbeth.
Welcome to the Greetings and Felicitations, a podcast where I explore topics which might not seem to be directly related to compliance but clearly influence our profession. In this episode, I discuss the recently released Tragedy of Macbethand a Harvard Business Review article. I use both of these different types of media to explore transformation in your corporate compliance program. Highlights include:
- Macbeth and descent into madness.
- Coen production of Macbeth.
- Transforming your compliance program through ‘you’.
- Why the user experience is so critical.
- The 3-step process to transform you compliance program.
Resources
The “New You” Business: How to compete on personal transformations by Lance A. Bettencourt, B. Joseph Pine II, James H. Gilmore, and David W. Norton
Over the weekend I saw Joel Coen’s The Tragedy of Macbeth on Apple TV. To say it blew me away would be putting it mildly. David Sims, writing in The Atlantic, said, “Shot in stark black-and-white by the cinematographer Bruno Delbonnel and staged on abstract, minimalist sets designed by Stefan Dechant, the film feels like a foggy memory of a story told a hundred times…With The Tragedy of Macbeth, Coen is stripping away that scenery, zeroing in on the essential details of Shakespeare’s tale of how a hunger for power can curdle into madness and death.”
It felt like I was watching madness descend in a German expressionist movie. I have always thought of Macbeth as exactly that; a descent into madness due to the murderous machinations of both Macbeth and Lady Macbeth, who were, in this treatment, played by Denzel Washington and Francis McDormand respectively. Both performances were Oscar worthy. Both actors, in their 60s, played the roles with a slightly different focus, which was succession. Not the great HBO show Succession but more what is their next succession. Over this week I am going to use Coen’s version of Macbeth to explore the questions of succession and what is next in compliance. Today, I want to take up the topic of transformation of your compliance program focusing on the ‘You’ in compliance as in the user.
In a recent Harvard Business Review (HBR) article, entitled “The “New You” Business: How to compete on personal transformations”, authors Lance A. Bettencourt, B. Joseph Pine II, James H. Gilmore, and David W. Norton posited that when companies “do promote what they sell in relation to consumers’ aspirations, they rarely design solutions that allow people to realize them. Instead, individuals must cobble together what they think they need to achieve their goals—for example, a trainer, a particular diet, and a support network to lose weight. Enterprises should recognize the economic opportunity offered by a transformation business, in which consumers come to them with a desire to improve some fundamental aspect of their lives.” It struck me that many compliance programs suffer from the same fate; that is, they do not focus on what the employee really needs. This also sounds very much like a Design Thinking approach for compliance which I wholeheartedly embrace. (Check out my podcast, Design Thinking in Compliancewith co-host Carsten Tams for a sampling.)
The first thing a compliance function needs to do is to have a solutions mindset. From there move to providing compliance transformations which help the business use the corporate compliance program to generate positive outcomes that your employees, whether business development folks or others, need to succeed. Compliance services will then be viewed in another light, as a way to help employees achieve both their and the company’s desired results. Employees have a role in this process and through engagement between the compliance function and employees in the design process, your compliance function will have more back-end engagement after the design process is implemented.
The authors have a three-step process which I have adapted for the compliance professional and corporate compliance function. The first is defining a successful transformation. The second is to ascertain the jobs to be accomplished and third, to define your success as the design and implementation proceed.
Defining a successful transformation means that you must understand what your employees are trying to achieve. The authors further break this done into four categories. A Functional job is one which represents a goal an employee is trying to accomplish or a problem they are trying to solve. Functional jobs tend to center on specific tasks leading to specific solutions. Emotional jobs address the feelings desire in the employment setting. It can be empowerment or simply being appreciated for a job well done. Social jobs concern how employees desire to be perceived or relate to others, such as with encouragement or empathy. Finally, there are Aspirational jobs, which the authors believe “sit at the highest level of what motivates people. They involve becoming who an individual wants to be: living life to the fullest, financially secure, successful careerwise, and so on.” The conclusion should be that there are several methods a corporate compliance function can use to understand employees’ jobs, including interviews, observation, and ethnography. The authors also caution, “Data alone won’t uncover what motivates people, what goals they have, or what problems they want resolved.”
Next, a compliance function must define success along the way. Here your compliance team “must spend time interacting with [employees] to understand what success looks like at every point along the transformation journey. You should consider what new understandings, decisions, and tasks are required for an individual to prepare, make progress, and sustain the desired compliance results. Here the authors suggest asking such questions as: “What would you like to see happen quickly? What problems or inconsistencies would you like to avoid? What does success look like?” By asking these questions you not only have employees engaged but you, as the compliance professional, garner a better understanding of the outcomes the business folks are trying to achieve. This in turn will facilitate your design. It could be something as simple as where and how employees can submit confidential issues to a corporate compliance function. It could be as involved in how to keep employees informed about the progress anytime they engage in “speak up.”
Finally, the compliance function must identify the barriers involved, “why they may stand in the way and figuring out how to assist in overcoming them.” These barriers exist in three primary domains which include resources, such as offerings, time, budget; employee readiness, focusing on skills, motivation, clarity; and the context of both when and where things are done. Here a corporate compliance function can and should consult their internal experts, “to understand what hinders success” and external specialists, who have studied particular challenges. These resources can also help identify deficiencies in the goods, services, and compliance experiences.
The bottom line is that compliance transformations are not produced solely by a corporate compliance function, “they are achieved in partnership with the person being transformed.” This means compliance must determine what expectations, know-how, and motivation employees need at every stage of their employment cycle and experience. The answers translate into solutions designed to guide the journey, equip employees thoroughly for their role in a transformation, and strengthen their resolve to persist in doing business ethically in the face of difficulty and challenge.
