Pop quiz: Do people in power always follow the rules established for their organizations?
Bonus question: Are these same people in power the ones we ask (demand, really) to sign attestations that their organizations are doing everything that they are supposed to be doing from a compliance perspective?
Interesting topic because it combines “Do as I say, not as I do” with “I’ll do my job, you do yours”.
Article by Jim Kim in FierceComplianceIT.
Emphasis in red added by me.
Brian Wood, VP Marketing
Compliance in the C-suite
A recent symposium held by the RAND Corporation, titled “Culture, Compliance and the C-Suite,” was held last month, producing a host of interesting papers and discussion.
One paper, from a Bryan Cave partner, offers a provocative thesis, which is that most C-suite execs operate all too independently of the company’s compliance structure.
In his view, the C-suite is a crucible in which several combustible forces converge, making for a unique environment. You have incredibly driven personalities faced with tremendous pressure to perform, given lots of power over others, and tremendous egos to boot.
“Things happen fast in this crucible, with urgency driven not only by business necessity but also by the inexorable demands of the quarterly reporting cycle. Quick decisions about complex problems are required, often involving forced choices between competing values. (What if skirting a costly environmental requirement will save hundreds of jobs?)”
An early casualty all too often is ethics, which can prove to be a slippery slope that ends with massive compliance lapses. The result of this mix of strong people in tough situations is simply stunning: “Over the past two decades, researchers in “behavioral ethics” have shown that an individual’s morality is much more malleable under situational and social forces than formerly supposed, and that most of the unethical behavior in organizations is committed by individuals who value morality and consider themselves ethical, yet regularly fail to resist temptation, or even to recognize that their decisions have a moral dimension.”
So you can have compliance lapses committed by people who are otherwise highly moral. That’s what pressure can do to you.
For boards, this crucible and its effects cannot be ignored as they ponder executive selection and critical risk management issues. Of course, boards operate within their own crucible.
Link to the white paper: