The life of a Chief Compliance Officer (CCO) can be intense and the one of the most powerful tools you have is persuasion. Jenny O’Brien, CCO at United Health Care, has talked about the techniques that a CCO can use to influence decision making in a company to do business in ethically and in compliance. She has called these techniques of persuasion “Seven Steps of Influence” and advocates a CCO employ them help influence decision-making within an organization.

  1. Collaboration. As a CCO you need to know your company’s business. If you are new to an organization you must take time to learn the business. You should sit in on sales meetings and, when appropriate, you should go out on sales call. Channeling your inner Atticus Finch, you must walk in the shoes of the business leaders you are assisting. By doing so, you will not only understand the products and services that your company offers but also the challenges that your business development team faces out in the world.
  2. You must work constantly at active listening, which is listening, thinking and then speaking, and not just jump into the middle of a conversation, talk to people in a manner that will address their concerns. When you do speak, be prepared to make the case for the compliance proposition that you are trying to get across. As a CCO, strive to be relevant in every interaction you have with your peers in senior management. This sometimes it means speaking up at meetings or other forums but sometimes it means listening. Develop a rapport with your business team and this rapport can lead to trust building.
  3. Relationships. This is relationships between the compliance function and other corporate functions in an organization, through a CCO or compliance practitioner can bring influence to bear. It all begins with building trust with others within your organization. Invest time to find others in your organization with which you want to work and with those with whom you desire to build relationships. The key relationships that a CCO or compliance practitioner can develop are with the audit function, the legal department, Human Resources, IT and corporate communications.
  4. Humility. Humility is important because it empowers. It can empower others to expand the circle of influence and get others in a corporation to influence an ever-expanding circle on behalf of compliance. The CCO does not need center stage. Echoing the DOJ Evaluation of Corporate Compliance Programs requirement that compliance should be operationalized, business units should solve compliance issues, as compliance is just another business process. Through such influence you can get business unit resources to solve a compliance problem, you will hold down the costs of the compliance function. It is not about being right but about moving the compliance ball forward in the right direction.
  5. Negotiation. A compliance practitioner you need to learn the art of compromise. Negotiation is not about the dichotomy of winning and losing an argument or debate. A CCO should strive to redefine what a win might look like or what a win might consist of for a business unit employee. When faced with such a confrontation, try to determine what both sides wanted then give them something else in addition to what they thought they wanted. A CCO can be considered a mediator not just simply an enforcer or Dr. No from the Land of No.
  6. Triple ‘C’. Keep calm, cool and collected because all company employees, up and down the chain, are watching the CCO. For this reason, a compliance practitioner should channel their inner Harry Dean Stanton and have a laconic face, at all times. The Triple C’s are important because organizations look to the CCO to solve complex issues with simple solutions. When faced with a compliance issue or an obstacle you should endeavor to keep everything on an even keel and never let them see you sweat.
  7. Credibility. The final of the seven pillars was that the CCO role needs to be adequately scoped and that the accountabilities need to be clearly defined. Put another way, what is your job scope as the CCO and what is the function of the compliance department? What is your accountability to decide the resolution to an issue? As a CCO, you must demonstrate your value as a non-revenue function. This may require you to get out of your office and put on a PR campaign for compliance. A CCO needs to guard their independence in job function and reporting. You must make clear that you will have independent reporting up to the Board or Audit Committee of the Board.

Influencing and using persuasion is not a one-time activity. It is ongoing. If you consider it within the context of the 360-degree approach to communication, it means calibrating every which manner of influence and with all your stakeholders, both inside and outside your organization. Persuasion touches all forms of communications whether those are formal communications, informal communications, or simply accidental communications. It includes using all the right methods of communications to maximize the influence you can bring to bear.

Three Key Takeaways

  1. Persuasion is probably the key tool for any CCO.
  2. Persuasion touches all forms of communications.
  3. Influencing, using persuasion is not a one-time activity; t is ongoing as in literally all the time.

 

This month’s podcast series is sponsored by Dun & Bradstreet.  Dun & Bradstreet’s compliance solutions provide comprehensive due diligence reporting and analysis to reduce your risk of working with fraudulent companies by accessing a company’s beneficial ownership, reputation risk and more.  For more information, go to dnb.com/compliance.

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