Increase compliance effectiveness
I’ve done considerable work in the area of compliance. I have also served on close to forty boards of publicly-held companies, banks, and insurance firms; as well as the Committee of Sponsoring Organizational of the Treadway Commission (COSO) taskforce. And, my research has been quoted by more than 250 organizations worldwide, starting with the SEC, Congress and The Wall Street Journal.
What this experience has revealed is a basic shortcoming with compliance legislation, regulation, and after-the fact monitoring (audits) that we see every day. Corporate Integrity Agreements, hotline overload, executive turnover, reputation risks continue to stunt organizational progress.
Risk reduction should be our goal in compliance if we are interested in adding value to an organization. We don’t need more laws and personal liability. Wallowing in minutia or and post fraud investigations will not deter or prevent fraud either.
We need to get to the heart of compliance.
There is a saying that the heart is the source of all good and evil. If that’s true, we don’t need a “fraud triangle” (a theory that pressure, opportunity and rationalization drive such acts) to understand the problem.
Instead, we need insights into human behavior. For instance, if the heart drives our thinking, actions, interactions, emotions, integrity, character, greed, motives and ethical decisions, then fraud is a heart condition.
You don’t change the heart with classroom training, it takes coaching, accountability, transparency and a host of other critical qualities and characteristics to drive better decision making.
What if we could win people over to a new outlook? What if we start with helping them see that poor behavior always catches up to them? What if we provide research that supports that fact and explore the benefits of honesty that stimulates a different way of thinking?
One preventive measure is to augment existing skills based training by developing essential qualities and character attributes that lead to peak performance, reduced risk, and lower turnover. Focus on developing core competencies like confrontation and courage (especially the ability to engage in difficult dialogue with bullies and wrong-doers) which are major factors in stopping abuses from escalating.
Here’s a list of some competencies that can be developed, and the expected outcomes.
Also, fraudsters are repelled by transparency and trust—especially with training resources that performance metrics that augment skills based training.
When we develop character attributes and better thinking, it lowers risk and improves profitability, as exemplified in this public company. Compliance coaching affected their culture, profits, engagement, management, service culture, IT, finance, HR, supply chain and sales effectiveness.
And let’s measure all improvements at both the macro level (key performance indicators) and at the individual level to show that integrity pays.
It’s time to get to the heart of corporate governance.