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Harry Cassin
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Richard Bistrong
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Richard Bistrong: The best compliance officers make themselves vulnerable

When compliance leaders ask, “What can I do to better connect with the work-force?” my response is always the same. I encourage them to show their vulnerability.

How? By recognizing that no one experiences risk more than the people who work in the middle of it, and that sometimes even a well-intentioned compliance program can miss that risk.

Compliance leaders who share their own humanity can more easily encourage commercial leaders to speak up about a compliance or ethical dilemma. The phenomenon is what trial lawyer Gerry Spence describes as,”You show me yours, and I’ll show you mine.”

But if compliance leaders need to demonstrate their humanity (and humility) by acknowledging that they might not always get it right, and the workforce needs to reciprocate by sharing their issues before they become front-page problems, then one bridge is needed: Trust. And as Barbara Kimmel shared on the FCPA Blog, that’s a commodity in corporate decline.

Trust was also the topic of an article by Paul Zak in January 2017 issue of the Harvard Business Review. He said a strong connection among colleagues isn’t just “a feel-good” phenomenon; rather, it’s one that “consistently leads to positive outcomes for both individuals and organizations.”

Zak shared research that supports the relationship between trust and economic performance, resulting in “higher productivity, better quality products and increased profitability.” 

Those are all outcomes that a compliance team can thankfully impact. Here are a couple of steps compliance professionals can take today:

Build authentic relationships. A Google study Zak cited found that “managers who express interest and concern for team members’ success and personal well-being outperform others in the quality and quantity of their work.” For a compliance leader, that might be an occasional reminder to the workforce that you’re their partner, that you want them to be successful, and you want them safe and back home with their loved ones.

The goodwill and trust that an attitude of care creates will be helpful when conflict and struggles inevitably arise. Someone is certainly more likely to reach out to another when a bond has developed before the moment of conflict came. As a clergyman once reminded me, “Richard, don’t try to build a foundation in the middle of a storm.”

Ask for help. Zak said “leaders in high-trust workplaces ask for help from colleagues instead of just telling them to do things.” Research, Zak said, found that “asking for help increases trust and cooperation.” (Ben Franklin was famous for asking for help from people whose help he needed. It’s even called the Ben Franklin Effect.)

Compliance leaders should ask the business folks if the company’s compliance program will meet the real-life challenges they face. And if there’s a gap, query them as to how it can be fixed. As one CEO shared with Zak, when he was open with his team about “the things I did not know,” it “helped me build credibility.”

Indeed, asking for help is a sign of a secure leader, Zak said.

*     *     *

Authors note: My thanks and appreciation to the editors and readers of the FCPA Blog for your trust in me. With the successful completion of my supervised release, I woke up recently for the first time in a decade not as a ward of the U.S. judicial system. I’m grateful for all of the support I’ve received from the FCPA Blog community. And while probation is over, my blogging is not!


Richard Bistrong is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLC. In 2010 he pleaded guilty to a conspiracy to violate the FCPA and served fourteen-and-a-half months at a U.S. federal prison camp. He now consults, writes and speaks about compliance issues. In 2015 he was named one of Ethisphere’s 100 Most Influential in Business Ethics. He can be contacted by email here and on twitter @richardbistrong.

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  1. A couple of points, Richard. First of all, congratulations on completing your probation and – along the way – becoming an important voice among those working to further the cause of decency in business. I know you could have chosen just to do your time, keep clean and move on, leaving a difficult past to disappear in the gathering shadows. That you did not do so, that you turned instead to using that past to connect with and become a leader within in the field of “applied ethics” is to your credit and our benefit.

    As to your post, I agree that asking for help often leads to receiving it. Asking for help is, after all, an extension of trust to the person you’re asking. Extending trust, in turn, engenders trust, and that, I agree, is a critical commodity in too short supply. Just as she or he earns trust by extending it, however, the successful compliance leader is more likely to be helped when she or he is helpful; not occasionally, not incidentally, but systemically.

    Both in my time as a CCO and in working with many compliance teams in the years since, I’ve seen clearly that aligning the compliance function, as well as the people who lead and staff it, with the day-to-day interests of the organization as seen by the people who lead and staff it is at the heart of effective, sustained compliance. Compliance teams succeed when the people they work with (including those to whom they report) see them as helpful. The compliance leader’s first question should be, “what are we trying to achieve?” The second one is, “how can I help get us there?” “What are the regulatory burdens that are gumming up the system, and how can compliance with them be continuously simplified and improved?” “What worries my CEO and CFO, and my team leads and the folks on the line in Penang and Mumbai and Morristown?” "Can I help them address those worries?"

    These are only starting points, of course, and compliance leadership comprises a complex set of tasks. But the compliance leader who can’t or doesn’t walk the shop floor as well as Mahogany Row, or leaves to others the business of the business, cannot succeed. The same is true of the compliance leader who views every employee and every part of the business first as a risk to be identified and mitigated. Simply put, the compliance leader who doesn’t both trust and help, will be neither trusted nor helped.

  2. Richard,

    Congratulations on your full and final release. You more than deserved to be a free man. Thank you for your blogs that always show the human side of organisations and individuals involved in bribery. Please keep it up


  3. Dear Wayne and Frank: On the personal side, thank you both for your kind comments. Your support through this journey has been nothing short of inspirational, especially in the context of your own enriching experience and practice in the field. Again, thank you for taking the time to share your reflections, and Wayne, your concluding sentence is now bound for a slide on my presentations: "Simply put, the compliance leader who doesn’t both trust and help, will be neither trusted nor helped." I couldn't agree more, and if compliance leaders want to be seen (and heard) as more than a regulatory guardrail, those "simply put" words of wisdom shoud be seriously considered and embraced. Best regards, Richard

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