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Tom Fox from Venice: Compliance professionals should get out more

Today is a Travel Edition from Venice. If there is one thing that’s ubiquitous throughout this city it’s the Gondolier, the Venetian Gondola boatman. You’re never far from hearing their cry of “Gondola, Gondola” to attract tourists for a fabled and romantic gondola ride.

One thing I notice about the Gondolier is that in addition to having a stout pairs of lungs, they’re almost all in very good physical condition. They have to be, piloting this very old craft by hand in and around the crowded waters of Venice.

I thought about this as a metaphor for improving your compliance program.

As a chief compliance officer (CCO) or compliance practitioner, the more you can get out of the office, into the field to meet the troops, the more fit your compliance program will be. Any best practices compliance program should have input from the geographies, cultures, business units and corporate functions within the company. It is well understood that a compliance procedure that works well in the U.S. may not work in Indonesia.

This means a CCO or compliance professional needs to understand how the cultures in your organization work and then create a compliance program to fit those needs. It does not mean a company can continue to do business with corrupt intent but if there is a culture of gift giving in a geographic area, you should determine a way to continue such courtesies, within the context of your overall compliance regime. You also have the opportunity to get out of the home office and visit international locations. This is the best way to find out what is going on in the field. In the compliance arena, your primary sources are the employees in your own organization.

When you meet with your international sales team, my corporate experience is that they will appreciate that you took the effort to travel to train them or meet with them. They are also more likely to tell you things in person that they wouldn’t talk about via email or over the phone.

One of the criticisms of anonymous hotlines and other internal reporting mechanisms is this lack of the personal experience that can lead to mis-trust if not distrust. Getting out into the field and meeting folks can go a long way to overcome this frailty of human nature.

Finally, by getting out of the office and working directly with other company personnel, you can set expectations appropriately. This is true whether you’re dealing with third party vendors in the supply chain, agents and other foreign business representatives, your employee base, senior management or the board of directors.

My observation that Gondoliers tend to be physically fit ties directly to the job they have to do — propelling a gondola. And as a CCO or compliance practitioner you can get out of the office and make your compliance program more robust and get it in better shape.  


Tom Fox is a Contributing Editor of the FCPA Blog. He has practiced law in Houston for 30 years. He is now the Compliance Ambassador for the Red Flag Group. He’s the creator of the award winning FCPA Compliance and Ethics website. His best-selling seminal book, “Best Practices Under the FCPA and Bribery Act: How to Create a First Class Compliance Program” (available from Amazon here) is widely viewed as one of the top volumes on the nuts and bolts of compliance.

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1 Comment

  1. There're lots of examples you can use other than Gondoliers but we got your point. I have been pushing this idea to the management of my previous and current employers but fell to deaf ears. The question has always been "how does letting the compliance personnel out improve the company's ROI or profitability?"

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