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Compliance officers can only succeed together

Michael Scher’s post, The real code of conduct nobody mentions, brought this to mind.

In 1988 Robert Jackel wrote Moral Mazes, a ground-breaking book of corporate culture. Herein he addresses the fundamental rules of organizational life:

1. You never go around your boss.

2. Tell your boss what s/he wants to hear, even when your boss claims s/he wants dissenting views.

3. If your boss wants something dropped, drop it.

4. You are sensitive to your boss’ wishes so that you anticipate what s/he wants; you do not force her to act like a boss.

5. You job is not to report something your boss does not want reported, but rather to cover it up. You do your job and keep your mouth shut.

CO austerity degrades the function, asking the CO to address the increasing risks they face with fewer resources. This does not bode well as future issues of malfeasance arise.

In addition, good CO jobs remain scarce. CO’s feel vulnerable. Do they conform to the system, and express fealty to the kings of the company? Or do they act with independence? It takes courage. Failing to act, however, is fraught with peril. To look the other way invites it’s own risk.

We can only succeed together.

With collaboration, and a deep, trusting sense of community, we will live to fight another day.


Keith T. Darcy is the Executive Director of the Ethics & Compliance Officer Association. He has combined a 40-year career in the financial services industry with deep experience as an educator in business ethics, corporate governance, and organizational leadership. He can be contacted here.

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