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Are ‘peer reviews’ for compliance officers a good idea?

Crowdsourced performance appraisals are all the rage in corporate life, with peers constantly rating how well or poorly co-workers are doing their jobs. Do peer reviews result in better compliance departments? Or, do they drive out the best and brightest compliance officers and damage the enterprise?

Fans of peer reviews (sometimes called 360° surveys) argue that collaborative evaluations and ratings are always more accurate than single-person appraisals. They cite surveys saying peer-reviewed employees feel protected from petty or vengeful bosses, are more satisfied with their jobs, and perform better than single-reviewed employees.

Critics don’t buy it. Their research shows that peer reviews lead to mainly negative feedback. That’s a problem because too much negative feedback doesn’t produce any improvement in performance. Instead, it usually results in the criticized employee finding other people to work with, either in the same organization or someplace else.

Critics also argue that peers who rate peers are always statistically unreliable. Why? Because the raters are never a random sample. Instead, all raters come from the same company, often from the same department, and probably work with, for, or under the person they’re rating. Any ratings they give in the peer-review process are therefore subjective and tainted by self-interest.

Who’s right? Probably there’s some truth in both positions. That is, peer reviews done right can contribute in a positive way to a company’s culture and to its employees’ performance. But done wrong, peer reviews are likely to damage a culture and drive off the best employees.

But let’s get specific. What about compliance officers? Do peer reviews work for them?

I doubt it, and here’s why.

Compliance officers are corporate gatekeepers. Their core function is to help the company and its people stay out of legal and ethical trouble. In that role, compliance officers need some level of independence, skepticism, and the ability and willingness to sometimes say, “No, we’re not going to do that.”

Gatekeepers who do their jobs well don’t win popularity contests. They aren’t members of the in-crowd. They’re permanent outsiders and natural targets for resentment and opposition.

So, can those under the watchful eye of a gatekeeper provide a reliable rating of that gatekeeper? Not likely.

What about compliance officers reviewing fellow compliance officers? Does that work?

Again, I doubt it. There’s too much self-interest in play. If I’m rating a supervisor, I probably have in mind to someday replace them. That thought, whether articulated or not, will color my review and rating.

What about reviewing a compliance officer who’s on my same level? That won’t work either. It’s a near certainty we’re somehow competitors and know it. Forget an objective review.

All that self-interested distortion is why Marcus Buckingham, a critic of 360° surveys, calls the results “gossip, quantified.” And let’s be honest: Swirling around any compliance officer trying to do a good job will be plenty of “gossip, quantified.”

Still, accurate job-performance feedback is something everyone needs. Constructive criticism is helpful. Honest appraisals can help guide teachable employees to a promising future.

What’s the best source for accurate feedback?

A generous, thoughtful, and fair-minded boss is one source. Such bosses exist and can magically elevate anyone fortunate enough to be in their orbit.

Another, and perhaps better, source is self-evaluations. Anyone who puts themself through a truly honest (and usually painful) process of self-evaluation will come out better for it. Self-revealed knowledge has a special power.

For every compliance officer, then, a brave look inward is always a good idea, and even better when there’s a fair-minded supervisor around.

But peer reviews for compliance officers? No thanks. The gatekeeper’s job is already hard enough.

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1 Comment

  1. Oxford Advanced Learner’s Dictionary defines peer review as follows: “a judgement on a piece of scientific or other professional work by others working in the same area”
    A compliance officer is often the only one working in the compliance area within the company. Therefore I would have assumed a peer review of a compliance officer to be performed by other compliance officers, from different organizations.
    What you are referring to under “peer review” in your article is an internal assessment process, like a 360° feedback. This is a good tool in order to assess how you are perceived from your interactions with others in the company, but as you say it is rather ineffective or biased to evaluate your effective proficiency or professional skills.
    I believe external peer review, i.e. a review (even partial and informal) performed by one or several executives from other companies but doing the same job may lead to progress. This exercise necessarily entails on the part of the compliance officer under review a preliminary effort of documentation and presentation.
    In fact I have done it as a Chief Audit Executive, not as a Compliance Officer, but I think it should be similar.

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