neville-marrierSir Neville Marriner died on Sunday. For any aficionado of classical music, Marriner’s contribution to the genre was immense, having founded the chamber orchestra, Academy of St. Martin’s in the Fields in 1958. The group was named for a church in central London where it held its early public performances. According to his obituary in the New York Times, the “group’s recording of Vivaldi’s The Four Seasons was a best seller in 1969, as was its soundtrack to Amadeus, the hit 1984 film about the life of Mozart, which sold more than 6.5 million copies, reached No. 1 on the Billboard classical albums chart and won a Grammy.”

However, Sir Neville was not just a prolific musician as “he also figured prominently in debates over how music from the early modern period — such as the work of Mozart, Bach and Handel — should be played in the present day. He advocated smaller, more agile groups for early music, and he remained committed to playing that repertoire with modern instruments, even as an insurgent movement urged a return to instruments and styles that had been in use in the 17th and 18th centuries.” He “dismissed the insurgents as “the open-toed-sandals and brown-bread set””. “The New York Times music critic John Rockwell wrote in 1987 that Mr. Marriner was “our most stylish conductor of what might be called the centrist early-music movement.””

I thought about his glorious recorded version of The Four Seasons when I read an Op-Ed piece in the Wall Street Journal (WSJ), entitled “The Culture Ate Our Corporate Reputation”, by Lou Gerstner, a former chairman and Chief Executive Officer (CEO) of IBM and RJR Nabisco. He had some very interesting views on what went wrong at Wells Fargo and indeed a wide variety of other companies which have sustained compliance failures. Initially, he noted, “This is not the first time I have seen corporate leaders blame a flaw in the “culture” for major shortfalls in their company’s performance. I believe this represents a serious misunderstanding of how institutional culture is created and the role it plays in defining corporate behavior.”

The problem is not the do what I say, not what I do problem that bedevils many parents but rather problem is “cu Rather it is a derivative. It forms as a result of signals employees get from the corporate processes that structure their work priorities”. This is directly translated into compensation as Gerstner says it “is one of the most important of these processes. If the reward system pays a premium for one kind of behavior, that’s what will determine employee behavior—regardless of the words enshrined in the value statement.”

Gerstner cautions, “If the financial-reporting system focuses entirely on short-term operating results, that’s what will get priority from employees. If you want employees to care a lot about customers, then customer-satisfaction data should get as prominent a place in the reporting system as sales and profit.” He concludes this section by asking the question, “Is it the leaders in meeting financial targets—or is it those who raise concerns regarding marketing programs that give priority to corporate goals at the expense of true customer needs?”

In the area of senior management communications to the troops, Gerstner mandates that not only does the appropriate ‘tone at the top’ have to be set by the CEO, it must be reinforced, followed and not denigrated or changed. He cited to the following example to illustrate this final point, “All too often, the CEO in his or her state-of-the-union address in January will proclaim a commitment to investing in the future, seizing new growth opportunities and accelerating R&D expenditures. And then six weeks later in the middle of February comes a memo from the chief financial officer stating that first-quarter budgets are running behind and all discretionary expenditures are to be put on hold and all new hiring is to be suspended. Now which of those communications do you believe shapes employees’ view of what really matters and, therefore, what they see as the true cultural priorities of their company?”

Another area Gerstner mentioned, yet which is rarely discussed by a Chief Compliance Officer (CCO) or compliance practitioner, is budgeting. Gerstner asks how often “sincere expressions of commitment” to compliance are washed aside when there is a monetary request to follow through with a new technology, risk assessment, gap analysis of internal controls or other compliance related expenditure. He writes, “The budget process is almost as powerful as the compensation process in shaping corporate culture.”

Gerstner believes it is “the cumulative effect of all of these processes: compensation, performance measurement, recognition, etc. that shape what we describe as corporate culture.” He challenges “any CEO who wants to understand the real culture in his or her company: Do not look at the value statement in the new employee handbook. Go deep and understand what each process in the company is telling employees is important. Again, people do not do what you expect but what you inspect.”

For Wells Fargo, it certainly inspected the number of sales made by its employees of banking products and services. “Eight is Great!” was the corporate mantra for the number of products each customer was required to hold with the bank. Employees were measured on it for bonuses, raises, job security; as often as four times per day when their managers would ask them how many sales calls they had made that day.

Gerstner concluded his article with “Don’t misconstrue my message: Creating expectations and communicating goals is a worthy and important responsibility of corporate leaders. But if these are not followed up on by a comprehensive and continual assessment of the alignment of all major corporate processes with those goals, the leaders will be listening to the sound of one hand clapping.”

Compliance professionals would do well to heed this warning. While you are at it, sit down and put on a CD or better yet full album recording of Sir Neville Marriner leading the Academy of St. Martin in the Fields through the glory of Vivaldi’s Four Seasons.

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