One of Mary Barra’s first acts as CEO of General Motors was crazy. The HR department and others opposed it. But she went ahead anyway.
She replaced the company’s 10-page dress code with just two words: “Dress appropriately.”
Her target was GM’s stifling hierarchal culture and bureaucratic mindset. The new two-word dress code — Dress appropriately — said to supervisors: “You’re accountable to lead your team. Go do it.”
It worked. GM’s culture shifted. People felt empowered. They became problem solvers.
“If you let people own policies themselves — especially at the first level of people supervision — it helps develop them,” Barra said.
Is there a lesson here for compliance? Could a company ever replace a 50-page anti-corruption policy with three words: Don’t pay bribes?
Would supervisors, managers, and executives take ownership of a three-word policy? Would they, as Mary Barra’s first-line supervisors did, become problem solvers in ways a centralized compliance group had never thought of?
Some of that might happen. But let’s be real. Compliance isn’t the same as a dress code.
Wearing blue jeans and flip-flops to a meeting with government auditors might be foolish and embarrassing, but it’s not a felony. Whereas offering too much corporate hospitality to a foreign official could be a criminal act, and people might go to jail.
A three-word compliance policy would freak out the company’s lawyers, for good reason. How do you prove you tried to comply with the FCPA or UK Bribery Act unless you have a 50-page policy that says so?
Still, Barra’s approach to the dress code is important. It goes to the heart of the culture question. She knew from her 30 years at the company, starting on the factory floor and working her way to the top, that GM’s first-line supervisors would never truly own a policy imposed from above.
So let’s ask: How far toward a “Don’t pay bribes” approach to compliance can a company go? If not all the way, is there middle ground, somewhere between three words and 50 pages, that might work better?
There are lots of reasons why a truncated compliance policy might not work. Just as there were lots of reasons why Mary Barra’s two-word dress code was a dumb idea.
But change doesn’t always come in predictable ways. Maybe there’s someone out there now, like Mary Barra, who understands better than anyone else how their company works. And maybe that person already has a crazy idea about how to do compliance better.
Richard L. Cassin, pictured above, is the publisher and editor of the FCPA Blog.