Vivaldi-the Four SeasonI return to my Travel Edition themed blog posts today. One of Venice’s greatest citizens was Antonio Vivaldi. His work is celebrated throughout his home city. Last night, I saw a performance of his most famous work, The Four Seasons, which is a piece composed of four violin concertos depicting scenes appropriate for each season. The inspiration for the concertos was probably the countryside around Mantua. They were a revolution in musical conception: in them Vivaldi represented flowing creeks, singing birds, barking dogs, buzzing mosquitoes, crying shepherds, storms, drunken dancers, silent nights, hunting parties from both the hunters’ and the prey’s point of view, frozen landscapes, ice-skating children, and warming winter fires. Each concerto is associated with a sonnet, believed to have been written by Vivaldi, describing the scenes depicted in the music.


The venue for the performance was a deconsecrated church and the sound was phenomenal. A former member of the Houston Symphony Orchestra once told me you can tell a great concert venue if “you can see the music” and tonight I could see it. It was performed by an octet so I could focus on the sound from the individual musicians and it was magical. While doing so, I was also able to better see how it all is structured and integrated together.

One of the things I hear most often from Chief Compliance Officers (CCOs) and compliance practitioners is that they do not have the time to take a step back and look at the larger picture of their compliance program to see how it is structured and how it all inter-relates. That is one reason I developed my service offering I call the Compliance Retreat. The Compliance Retreat allows you to work through a wide range of compliance issues specific to your company, your risk profile, your industry and your culture. It will allow you to see the structure of your program and then think differently about your complete and integrated program, all facilitated by one of the top Nuts and Bolts compliance practitioners around.

The role of facilitator is crucial for several reasons. First and foremost, you should have a neutral party, one with no stake in the outcome. This means that you should not bring in your regular counsel or compliance advisors because they will have a vested interest in projects moving forward. Further, the facilitator needs to be well versed in not only the anti-corruption compliance field but also someone who has seen a wide variety of best practices in compliance in multiple business and industries. In the compliance field many practitioners want to know what other companies are doing and how they are facing unique challenges in many areas. Only an expert in the compliance arena can bring all of these skills to bear.

It starts with a Facilitator prepared to discuss your compliance program; the current structure, risk assessments, audits and outstanding issues at this time. A Facilitator could then help lead a discussion based on wide compliance discipline knowledge for steps to consider in building your program. From there, you can move towards building out and enhancing your own compliance program. It would end with action steps that can be measured moving forward.

The Compliance Retreat is more than simply getting away for one day to discuss the specifics of your compliance program. Sarah Kessler, writing in, in an article entitled “How to Plan a Company Retreat”, listed some of the key principles of a strategic retreat that I have adapted for the Compliance Retreat. They include:

  • Collaborate. Make certain that all participants have the ability to collaborate.
  • Make discussion introvert-friendly. Ask the participants to write down answers to questions instead of blurting them out, and ask every person in the room to give their opinion in an organized manner.
  • Encourage people to express themselves. It is important that all opinions are heard and make certain that minority opinions have a way to be heard.
  • Combine team building with work. Compliance is always about teamwork so your compliance team should decide their next steps in the future, versus just experiencing a task together and deciding that the group can simply work well together.
  • Stay on topic. It is important to stay focused on compliance issues.
  • Diverge, converge. You should break up your group for more focused discussions then bring them back to the larger group for discussion.
  • Document your next steps. Assign a champion for each step that the compliance team has agreed on, making those steps as specific as possible. You should document who does what, when they will accomplish the task and how, at the end of the day, you will measure it.

Through my new service offering the FCPA Master Class Training I am bringing the most current best practices on the nuts and bolts of FCPA compliance to a wide variety of compliance practitioners across the US. With the Compliance Retreat I will be able to offer the best practices to any compliance department or similar corporate function that wants to have a focused retreat on its compliance program. You will have the time to step back and take a look at the bigger picture. Imagine you could focus for one day on your compliance program and be able to pick the brain of the one of the tops Nuts and Bolts compliance practitioners around.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at

© Thomas R. Fox, 2016