Tomorrow, on June 1, the world will celebrate the 50th anniversary of the release of what Rolling Stone called the greatest album in the history of rock and roll, Sgt. Pepper’s Lonely Hearts Club Band. As the magazine noted, “it is the most important rock & roll album ever made, an unsurpassed adventure in concept, sound, songwriting, cover art and studio technology by the greatest rock & roll group of all time.” Not satisfied with those superlatives, the article also stated, “No other pop record of that era, or since, has had such an immediate, titanic impact. This music documents the world’s biggest rock band at the very height of its influence and ambition.”  It was a veritable cornucopia of “iridescent instrumentation, lyric fantasias and eye-popping packaging”.

As it is also my favorite album of all-time, I will be using it and its songs, themes and even album cover to “Pepper” my compliance related posts over the rest of the year. While the album was recorded as if by an alternative band, Sgt. Pepper’s, “only two songs on the album had anything to do with the Pepper characters: the title track and Ringo Starr’s vocal showcase, “With a Little Help From My Friends” introduced as a number by Sgt. Pepper’s star crooner, Billy Shears.” Getting the then somewhat reticent Ringo to sing was done by a design that only left Starr following his instincts in vocalizing the song in the studio. John and Paul waited until the end of a grueling 8-hour recording session and as Ringo was leaving told him to have a “go at it” which produced the iconic opening song on the album.

In a recent article in the New York Times (NYT) Corner Office section, Adam Bryant interviewed Elisa Steele, the chief executive of Jive Software, a provider of social networking software for businesses. Steele has some interesting insight for the compliance professional. In one of her early sales positions she noticed that “all of the account executives had their key accounts and their dog accounts. And they didn’t spend any time with their dog accounts, because they focused on the ones that were growing.” Sensing an opportunity, Steele went to “the sales manager and said: “Why don’t you give everybody’s dog accounts to me, and I’ll go see if I can do something with them. They don’t want to spend time with them, and I’m bored.” He agreed to the idea, and suddenly I was sitting there at my little cube, and I had 20 dog accounts.”

Steele commenced to scheduling time and met with each one of them. Not too surprisingly she related that “most of them said: “We haven’t heard from you guys in a long time. Good to see you.”” Through this insight and work, Steele was able to turn “some of those accounts into revenue-producing accounts.” For the compliance professional, the key insight is that compliance, like sales, is about relationships. If you do not get out and talk to your customers, i.e. your employees, they may well become the equivalent of “dog accounts”. When was the last time you got out into the field and met with your customer base?

Another important insight from Steele was simply the willingness to get out there and work. It came at the first time she was promoted to a general manager’s role, where she had responsibility for everything in the unit; including sales, tech support, customer service, Human Resources (HR), compliance and marketing. All of her direct reports were men nearly 15 years her senior. In her first meeting she said, ““We’re going to get to work.” Whatever they thought of me, they had been there, and the results weren’t good, so they were going to have to give me a chance. We figured out who was good at what and started making progress.”

For the Chief Compliance Officer (CCO), the clear insight is that you must support middle level management. This role is critical because most company employees work directly with middle, rather than top, management and, consequently, they will take their cues from how middle management responds to a situation. Moreover, middle management must listen to the concerns of employees. Even if middle management cannot affect a direct change, it is important that employees need to have an outlet to express their concerns. Therefore, your organization should train middle managers to enhance their listening skills in the overall context of providing training for what Steele termed their ‘Manager’s Toolkit’.

Yet, equally important, is the willingness to get down and work. This is simply more than being Dr. No from the Land of No. As a CCO or compliance practitioner, you need to get in the trenches and work to find solutions. Show the troops you are willing to roll up your sleeves to get things done. You will be surprised to see the return you get on this simple act.

Steele said that early in her career “I questioned my instincts. I wanted to follow the book. I was the student. I assumed everyone knew more. There were times when I didn’t follow my instincts and made mistakes. I realized in hindsight that if I had followed my instincts, there would have been a different outcome. So my biggest lesson is to follow your instincts. You know better than anybody else.” As a compliance practitioner, you are going to have to make gut calls so go with your instincts and do not look back. Closely tied to this point was Steele’s next: be prepared. It seems simple enough yet how many meetings have you attended when the participants were not prepared?

Steele considers team dynamics when hiring; whether you want to win as a team member. For any compliance professional, this is critical as compliance does not succeed in a vacuum or even as a stand-alone discipline. She also listens for “for decision-making skills — how quickly were you able to decide to do X versus Y? How long did the situation go on?” She ended by noting that “In any industry, you move so fast”; which makes the decision-making skill “super-important.” She tied the two together with inquiries around the team-oriented aspects of your decision making. For every compliance professional, this is critical going forward.

The 50th anniversary of the release of Sgt. Pepper’s Lonely Hearts Club Band is reason alone for celebration. But you can use the album, its themes and images to enhance your compliance regime. Just remember, as a CCO or compliance professional, you get by with a little help from your friends…

 

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 tfox@tfoxlaw.com.

© Thomas R. Fox, 2017

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