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Richard Bistrong
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Richard Bistrong: Would I hurt others to help myself?

Brunhilde Pomsel, from A German LifeAt the Cinema Village in Greenwich Village, one of New York’s last remaining arthouse movie theaters, I went to a screening over the holidays of A German Life. It was a brutal experience.

The New York Times described it as “likely to be the last new movie of its kind: a documentary that presents contemporary testimony from someone who witnessed the inner workings of the Nazi high command.”

The film centers on an interview with Brunhilde Pomsel, who served as Joseph Goebbels’ secretary and who was 103 when she was recorded, with video frequently punctuated by raw archival footage from WWII and post-war material.

It was natural to watch the film and to feel utter and complete revulsion at Ms. Pomsel’s testimony, as she struggles with her own guilt and complicity, being present and working at the epicenter of Nazi atrocities. She asks, “Is it bad, is it egoistic when people who have been placed in certain positions try to do something that is beneficial for them, even when they know that by doing so they end up harming someone else?” 

She describes her decision to join the Nazi party as, “Why shouldn’t I?” She talks about the workplace and professional benefits she would receive as a party member, as we might describe signing up for a music streaming service. In the end, she almost reluctantly admits that she was “one of the cowards.”

But oddly enough, as discussed in a New York Times article, “Ms. Pomsel’s personal guilt was not the directors’ main focus.” Rather, the movie makers wanted it to be a “reminder of the human capacity for complacency and denial.”

Taking it a step further, one of the directors, Olaf Müller, said: “One of the main aims of the film is to have the audience question: How would I have reacted? What would I have done in her situation for a new step in my career?”

I’m glad I read the NYT interview with the directors before I watched the film. Why? Because Olaf’s challenge made me uncomfortable. It caused me to think deeper than I otherwise would have, to imagine myself at that place and time, confronted with similar circumstances.

Like everyone, I’d like to think I know exactly how I would have reacted. We can all cast ourselves in the role of always doing what’s right,  especially with the benefit of hindsight.

But in our world today, where globally disbursed personnel face constant ethical dilemmas in their lives and work, and where subtle and obvious forces intertwine with emotional biases and decision making, these crucibles are powerful tools for business and compliance leaders to look deeper into the question, “What would I do?”

And Ms. Pomsel also provides a chilling reminder for commercial personnel to think beyond their own ecosystem, where corruption might look like a business win-win, without the calculus of “who am I hurting,” even if unintended.

Compliance leaders have a unique opportunity to embrace Olaf’s challenge. Here is where cross-functional teams can collectively struggle with ethical dilemmas in order to help safeguard the front-lines of operations. We don’t need to wait for a blog post, podcast or enforcement action to ask ourselves, “What would I have done?”

So many of these conflicts and challenges are inevitable and almost predictable, so why not surface them now? Why wait for an imminent crisis to face our future choices? As a clergyman once said to me, “The best time to build a house is when there’s not a storm.”


As a postscript, Ms. Pomsel died about a year ago at 106. She served five years of prison in the then Soviet Union, after her capture in the bunker where Hitler and Goebbels committed suicide.

A trailer for A German Life is here.

I wish everyone all the best for a Healthy and Happy 2018, with lots of difficult, challenging and uncomfortable conversations.


Richard Bistrong is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLCIn 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 was named to Compliance Week’s list of Top Minds in 2017 and was one of Ethisphere’s 100 Most Influential in Business Ethics in 2015. 

His popular real-life compliance training video, Behind the Bribe, produced in cooperation with Mastercard, was released in June.

To request a demo of the full eleven-minute video or a licensing fee schedule, please click here.

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  1. Richard,

    Excellent and thought provoking.

    The lessons learned are quite clear.
    – It highlights the need to look beyond corporate (or political) talking points and take a realistic look at the harm (or benefit) of a proposed course of action.
    – It highlights the need to understand that our actions (or inactions) are part of the web of human conduct and not put blinders on and think that if what our immediate actions aren't causing the foreseen harm that it is somehow okay.

  2. Richard Bistrong surfaces profoundly important issues here. However uncomfortable or even unanswerable, questions like “What would I do?” "Whom am I, or might I be, hurting?" retrospectively, “What would I have done?” and, in real-time, “What will I do?” should be taken up by everyone: ethics and compliance professionals, business leaders, corporate directors, citizens, parents, teachers, policy makers; truly anybody in a position of responsibility and influence. Subtle and obvious forces do indeed intertwine, as Mr. Bistrong astutely observes, and not only in the context of identifiable ethical dilemmas. In human affairs, the gap between intention and execution can often be measured in nano-seconds and micrometers. But it is nonetheless in real terms a chasm which cleaves an irreversible, sometimes irremediable, before-and-after scar in peoples’ lives. Mr. Bistrong is correct: these conflicts and challenges are inevitable and, armed with sufficient knowledge about their underpinning drivers and cyclical dynamics, absolutely predictable. There is no ethics, compliance, counter-fraud, cybersecurity, or anti-corruption program, system, protocol, or procedure, no matter how brilliantly devised and magnificently constructed, that will not at some point be defeated by a Brunhilde Pomsel, for those dispositions—denial, complacency, self-interest, indifference, and many others—are in each and every one of us. As we start this new year, my hope, and my pledge as a practitioner, is that there will be many more conversations about these issues.

  3. Dear Emeka and Alexander. First, my thanks to you both for sharing your reflections on the blog post. What you have written here gives me additional pause to think about this dynamic/peril and will certainly inspire a follow-on post. But you are both spot on- how can we inspire a globally disbursed work force to think about their conduct and decisions in a wider sense, in what Alison Taylor and James Cohen have called our 'hyper-transparent' world. And I agree with you both that these issues can't be surfaced, nor mitigated, via Emeka's '"talking points," or Alexander's "system, protocol, or procedure," because as Alexander shares, we all have some deeper emotions and biases that can't be 'policy and procedured'away. From my perspective, ethical struggle and uncomfortable conversations need to become a part of the corporate narrative, as to anchor those perils, and hence, make them visible, as part of the normal, healthy, corporate discourse. As I often share in my consulting work with compliance teams, the difficult conversations are the good ones, as that means everyone is leaning in together, and unpacking those biases and dispositions together. And as Alexander has shared before, when the time comes, in that split second where a decision needs to be made, all of that work when there is not a crisis at hand, just might come to fruition when someone asks for help and guidance, without being embarrassed or intimidated. Thank you again, and all the best for a healthy and happy New Year. Richard

  4. Very thought provoking post. Thank you, Richard. It reminds me of the conformity experiments by Ash, Milgram, Sherif, Zimbardo. Their findings underscore that, besides personality, context matters a great deal in how people answer the question "What would I have done?" The implication, not least for E&C practitioners, is that we also need to answer this question: How do we design the organization in such a way that it makes complicity less likely, and humane intervention more likely? In other words, what are the values we promote at work? Do we treat others fairly and with kindness? Do we listen and respond constructively, when employees speak truth to power? How do we support employees to resist injustice?

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