What should a company do when it desires to hire a Chief Compliance Officer (CCO). I sat down and visited with Maurice Gilbert, the Managing Partner at Conselium Partners LP. Gilbert believes that it behooves any company to find the right CCO or compliance practitioner for the right position. But to do so, a company needs to fully understand and appreciate what it needs from such a position going forward. Unfortunately, many companies do not have this insight at the beginning of the recruitment process.
The process often begins with the company supplied job description, which Gilbert noted is “typically a legacy of various things that are not even updated. It’s a hodgepodge of things that maybe began a few years ago, but it needs to be updated to reflect what’s going on in the company at that particular moment. You have certain business risks. You have certain regulatory risks…. You need to be attentive to those risks so that you could build your profile about what those risks need to be addressed presently.” Moreover, “what you’re going to get in a company job description is just a litany of things that actually could be quite disjointed and may not necessarily make sense for what you’re going to be asking the person to do.”
Gilbert will bring the key company stakeholders into an initial meeting to help them understand the process. Obviously, this will include Human Resources (HR) and others involved in the internal hiring process for the company. Gilbert gets them to rethink their approach to focus on what they will ask the new hire to accomplish because typically there is a disconnect between what the company thinks it needs and what it really needs.
The next step is developing an appropriate job profile. Gilbert will ask the key stakeholders to give him a list of four things they would like the new hire to accomplish in the first year of employment. By limiting to this to four, Gilbert not only ends unrealistic expectations but helps winnow down the inevitable “laundry list of, “We’d like the professional to accomplish 30 things within the first year.” Many of which, are inconceivable. They have to be done in the course of several years. When we’re listening to the response, we, again, are counseling our client as to whether that makes sense or if that’s an unreasonable, let’s say, expectation.”
Gilbert gave an example of a recent search he headed for a client. One of the things he was able to develop at this initial meeting was that the company wanted the CCO “to spend the first two, three months evaluating her staff, to see if she has the appropriate team in place for the rest of the journey. By the way, she’s traveling all over the world doing just that. Evaluating her staff.” However that task alone could take several months. The company also wanted the CCO to perform a comprehensive risk assessment immediately upon starting the position. It is simply not realistic to expect such disparate and time consuming tasks to be performed so quickly, all the while the new CCO would be expected to travel to company locations across the globe.
Another important issue in this initial meeting is the professional growth opportunities that the company will present to any candidate. Gilbert explained that this is something companies do not always appreciate in the hiring process. Yet, as he explained, a company is trying to get a seasoned executive to leave a position so they need to have an attractive package ready to present. It is more than simply salary and benefits. Gilbert said, “we have to capture data such as, “What are career growth options once a person steps in and does a good job for three, whatever, years?” We have to capture data. “What is the culture of the company? What is the culture of the compliance department? What are the hot buttons and the management strategy, if you will, of the hiring authority? How does that person like to interface with the individuals?”
A final query to the company is around the sourcing of candidates. Gilbert needs to know if there are any particular competitors, or companies, which the client feels are hands off for sourcing candidates from and before he leaves this meeting he needs to know the companies that his client does not want Conselium to recruit from.
I found these points quite illuminating for several reasons. First, the company was not clear on what it wanted the new CCO to accomplish and had not thought through what it would need to commit to in terms of resources to have these goals accomplished. The second demonstrated the communications flow facilitated learning on the part of both parties, i.e. for the client this was to have a realistic expectation of the new role and for Gilbert it was to help develop an appropriate Job Profile. It also demonstrated the collaborative nature of the relationship. By engaging in this process Gilbert is able to move from simply a third party executive search firm to a trusted advisor to the client. By having such a relationship Gilbert and his company, Conselium, are able to deliver a much more focused and valuable service beyond the typical generalist experience available inside a corporation in the hiring process.
From these discussions, Gilbert will develop a Job Profile and present to the company to have them sign off on not only the package of what they are looking for in a candidate, but also the package they will be willing to present. Gilbert related that through the capture of and agreement with these points, he is ready to begin the next step, which is to tell the compelling story about the job position on behalf of his client.
Three Key Takeaways
- Bring in your key stakeholders to flesh out the job description.
- Consider the top four things you would like a new CCO to accomplish in the first year.
- For a new CCO to succeed, the company must have a realistic expectation developed before the process begins.
This month’s series is sponsored by Advanced Compliance Solutions and its new service offering the “Compliance Alliance” which is a three-step program that will provide you and your team a background into compliance and the FCPA so you can consider how your product or service fits into the needs of a compliance officer. It includes a FCPA and compliance boot camp, sponsorship of a one-month podcast series, and in-person training. Each section builds on the other and provides your customer service and sales teams with the knowledge they need to have intelligent conversations with compliance officers and decision makers. When the program is complete, your teams will be armed with the knowledge they need to sell and service every new client. Interested parties should contact Tom Fox.