Something a little different today!

From the upcoming Wildly Strategic Compliance Officer Workbook

All of us enjoy working in a way that suits our personality and proclivities, but is your natural way of working helping you to be a Wildly Strategic compliance officer?  Perhaps you love to collaborate with other functions, or perhaps you’re the type who likes to run everything yourself.  Identifying your type can help you to see your own strengths and weaknesses, which in turn will allow you to strategically identify how you work with the business.

Quiz: What’s Your Type?

There are no correct or incorrect answers to the following questions.  Each type has its strengths and weaknesses, and each type is helpful in certain situations and problematic in others.  For each of the following questions, answer A, B, C or D.  Be honest – no one will know the answers but you!

Question 1: The board just found out about a data breach that has compromised the health records of 10,000 patients involved in a drug test your company is conducting.  Do you:

A.    Immediately declare that Compliance will handle this.

B.     Tell the board that you tried to warn them last year about cyber threat, and this is what happens when they don’t listen.

C.     Go in with a plan you developed with Information Security and Information Technology which will stop the leak and let you research whether you need to disclose the breach to the regulators.

D.    Continue to work on your risk assessment for next year – you haven’t explicitly been assigned data privacy.

Question 2:  You are the Chief Compliance Officer for an international food company that buys raw produce from farms using migrant labor.  The European Union has passed a law which will come into force in 18 months that requires supply chain audits to detect trafficked labor in supply chains.  Do you:

A.    Immediately outline a plan where Compliance is in charge of the risk assessment, training, an anti-trafficking policy and remediation of any violations of the new policy.

B.     Tell the legal department that there is a new law coming into force.  Laws are their responsibility.

C.     Prepare a plan with the Procurement and Human Resources Departments to train the local managers on the ground, and a request for a budget so you can get online training pushed out to everyone on the red flags associated with human trafficking. 

D.    Ignore it until the law comes into force in 18 months.  It may change in the interim anyway.

Question 3:  At the annual leadership meeting, the CEO says that ethics and culture are critically important, and that they should be a focus for the upcoming year.  You:

A.    Decide that Compliance should roll-out and Ethics and Compliance Week event next year, then schedule an appointment with the CEO for the day she gets back in the office to discuss your plan.

B.     Ask the Director of Human Resources why ethics and culture haven’t been handled effectively in the past.

C.     Call the Director of Human Resources to plan for a series of two-minute videos highlighting the company’s values, and brainstorm how the CEO, Compliance and HR can work together to highlight ethics at the company.

D.    Let this one pass- it was one statement, and it wasn’t even made directly to Compliance.

Question 4:  It’s your first day on the job as the company’s first compliance officer.  The Office of Foreign Asset Control (OFAC) fined your firm $1.9 million for violating sanctions laws on exports to various Middle Eastern countries.  You:

A.    Come in with a contract signed for sanctions-screening software and a pre-paid retainer to the best law firm you can find.

B.     Call a meeting with the existing Legal team to find out why they didn’t catch the problem in the first place.

C.     Call a meeting with the Legal team to figure out how you can share some of their resources in researching other sanctions which may cover the business.

D.    Are sure it’s fine- after a $1.9 million in fines, and the hiring of you to work in compliance, you’re sure the major problems with sanctions are under control.

Question 5:  You’ve been in charge of the compliance department for four years, and in the last 12 months, there hasn’t been a major issue or problem.  You:

A.    Begin your thorough risk assessment exactly as scheduled, only this time you use a stricter methodology to ensure you haven’t missed a thing.

B.     Email the third-party service running your whistle-blower hotline to complain that they aren’t doing a good job with their advertising/promotional material, since you haven’t had any calls.

C.     Request half-hour phone meetings with the heads of Internal Audit, Legal and Human Resources to see if there are any areas in which you can collaborate to work improve the program for next year.

D.    Nothing – you’re doing an awesome job!

Add Them Up

 Add up the number of A, B, C and D answers you gave.  Then read below to discover your Compliance Leadership Personality.

Mostly A’s: Authorities

 You know exactly what you’re doing.  You love being in charge, and you know that no one can do anything better than you can.  You’re skilled, you’re smart, and you hate it when other people interfere with your ability to get the job done right.  You’re the Authority, and you like it that way.

Strengths:  Authorities are great planners.  They love to be in charge and to make and execute the plans they have created.  They can be counted on and boards and C-suites love their proactive approach to their job. 

Weaknesses:  Compliance is an inherently complex job requiring the input and buy-in of many different areas of the business.  Authorities can pigeon-hole themselves, making it much harder to get things done.  Their initiatives may be blocked if they appear arrogant, which will fail to get the buy-in required from other members of the business.

Advice:  If you’re an Authority, be on alert to where other people and departments can help you out.  Be proactive in searching out others to whom you can assign various parts of your tasks.  Working together helps others to understand the compliance function, and this can make you much more effective.

Mostly B’s: Blamers

 If the business had just done things your way, they wouldn’t be in this mess.  You know what you’re doing, but they just don’t listen to you.  Sometimes people and businesses get what they deserve.  Hopefully next time they’ll listen to you so that you can properly do your job.  In the meantime, your expression and demeanor clearly says, “I told you so!”

Strengths:  Blamers are excellent at unwinding what happened and performing a post-mortem review.  Blamers can see what went wrong, which can be helpful in refining the compliance program, or helping the business to avoid the problem in the future.

Weaknesses:  Blamers are often stuck in the past, looking at what happened instead of pro-actively working to make the program better and to improve the situation.  Additionally,
most people don’t like to be publicly shamed or to have their failures pointed out, so blamers can easily become unpopular within a team.

Advice:  Separate the recognition of what happened from the personal responsibility of others.  If you’re able to opine or give advice about what to do next time without rubbing it in or shaming others, you’ll be much more effective.

Mostly C’s: Collaborators

 Your motto is, “Let’s all get together to get this project done!  If we all work together, we’ll be better off.”  You love to work with others and to get everyone’s input and buy-in.  You naturally want to involve the other stake-holders because you know that will help each project both in terms of buy-in and in terms of utilization of talent and subject matter expertise.

Strengths:  Your ability to work well with the other functions allows compliance to pull in the best of others.  You ensure that projects are completed efficiently, because there is no need to duplicate a skill set or assignment in compliance if it is already being completed by another function.  You are a team player and are likely quite popular with the business.

Weaknesses:  Working with others can create a leadership void, where no one has responsibility for getting a project or investigation completed.  You may struggle to complete your initiatives because you are relying on, and waiting for others to do their part.

Advice:  Be clear when you delegate parts of your projects so that everyone has the same expectation as to deliverables and timing.  Make sure that you’re on the same page with everyone on your team and in the different functions when you share responsibilities and that everyone holds themselves accountable to deadlines.

Mostly D’s: Deflector

 You think everything is going fine.  It’s going so well that it really doesn’t need input from you anymore, right?  You’re happy with the way things are, and you don’t want to rock the boat.  It’s not that you’re lazy (OK, it might be because you’re lazy), it’s just that if you start changing things, people may react badly.  The status quo is just fine with you.

Strengths:  You are good at maintaining continuity.  People know what to expect from you and generally get what they expect.  You feel safe and comfortable, so for many, you are easy to work with.

Weaknesses:  If you aren’t proactively looking after your program, it is likely to fall behind and fail to respond properly to new risks.  Your company runs the risk of believing that the compliance function is handling problems, when in fact it is simply ticking over day-to-day without a plan for fixing problems in the future.

Advice:  Balance your desire to maintain the status quo with a forward-looking risk assessment and annual goals.  You need to shake up your program once in a while.  Be proactive to give the business confidence that you can handle the job.

Knowing Your Type

 Once you know your type, you can look out for your strengths and weaknesses as you create and refine your compliance program.  Every type has strengths and weaknesses, and the more you are able to compensate for your weaknesses and highlight your strengths, the more effective you will be at your job.