Jeff Kaplan: Steve, over the years I’ve seen E&C officers struggle with the issue of how friendly they should be in their companies – particularly with managers. Is this something you’ve seen too? And, if so, what is the source of their struggles?
Steve Priest: It is a real tension Jeff. The source of the struggles is probably the human condition: we want to be effective, and we want to have friends. And unlike, say, psychotherapists, ethics professionals generally do not begin their jobs with training or even guidance on how to handle boundary issues. I knew one excellent E&C officer who believed a key to his success was his extensive network of personal relationships throughout the company. And another who would not even go out for drinks after work because he thought that blurred the lines. What’s your take?
Jeff: I agree that it’s a challenge – or, indeed, should be. In a way I’d worry more about those who don’t worry about this than those who do. I see the tension come up in various aspects of an E&C officer’s work. For instance, from a risk assessment perspective the holy grail is often to be involved at the earliest stages of business planning – going into a country for the first time, or developing a new product or service – and for that being a trusted advisor/friend can be essential. On the other hand, getting too close to management may make it harder to impose discipline for a manager’s failure to prevent/detect wrongdoing – because the closer we get to individuals the more biased in their favor we generally become. So, I agree that there are challenges – are there also solutions?
Steve: While in most matters I will advocate for the Aristotelian Golden Mean, in this I lean toward cultivating relationships. One of the pioneers in the field of business ethics, a wonderful man named Bill Giffin who started the Office of Business Practices at Sears, used to repeat like a mantra “We measure our success not by how many people we catch, but by how many people we help.” Ethics and compliance is primarily about preventative law, about helping people avoid problems and if this fails, identifying them early. I think you are more likely to achieve these goals if you are Andy Griffith than Wyatt Earp.
Jeff: I agree, Steve – at least for mature E&C programs. If you’re trying to tame a Wild West type organization, you may need to be Wyatt Earp – at least a little. But companies that have adopted the E&C officer as trusted advisor should recognize the dangers, and try to compensate for them in communications explaining all the means (e.g., a strong approach to reporting to the board) that are used to ensure E&C independence. Finally, as a practical matter, one needs to be sensitive to perceptions that can arise from the little things. For instance, an E&C officer who always sits with other senior managers in the office cafeteria might be seen as “one of them” – and be harder to approach by the rest of the workforce.
Steve: Little things. We have not talked about it much, Jeff, but the more work I do, the more I recognize the importance of little things. I just finished meetings that focused on trustworthy managers in Singapore, China and Japan, and person after person talked—with passion—about little things their managers did or did not do. Greeting by name, respecting time, reacting calmly to minor bad news, treating lower level employees the same as senior executives—these are all hallmarks of leaders trusted by their people. The same is true for ethics and compliance professionals. Imagine that. Or Andy Griffith, whose theme song should whistle through every reader’s head the rest of the day….