This week I have been exploring how to change the culture in an organization based upon a series of articles in the most recent edition of the Harvard Business Review (HBR) by Boris Groysberg, Jeremiah Lee, Jesse Price and J. Yo-Jud Cheng. We previously considered their lead article “The Leader’s Guide to Corporate Culture”. We next considered how you might move the needle forward on culture, in an article entitled “What’s Your Organization’s Cultural Profile”. Today I want to consider their final piece in the HBR series entitled “Context, Conditions, and Culture and ponder some more challenging leadership variables which a Chief Compliance Officer (CCO) might face in this effort. This is because “Context matters when assessing a culture’s strategic effectiveness. Leaders must simultaneously consider culture styles and key organizational and market conditions if they want their culture to help drive performance.”

The areas the authors focus on are: region, industry, strategy, leadership and organizational design. Yet I was interested in the area of leadership. Obviously tone at the top is important as both the character and behavior can greatly affect culture. I considered this when about Paula Kerger, the Chief Executive Officer (CEO) of the Public Broadcasting System (PBS). She was profiled by Adam Bryan, in a New York Times (NYT) piece entitled “Find the Courage to Take a Scary Leap”. Kerger identified cultural change as the “biggest challenge for leaders, and it’s also the thing that will kill you if you can’t figure out how to manage what is clearly a shifting landscape, and get people moving along that path and not be stuck.”

Kerger said that PBS has gone through such a change, by noting “We’re going through a big rebuild of our whole infrastructure of how we distribute our content. When you get your head around it, it’s such an extraordinary time, and it’s not one for the faint of heart.” Many companies who have gone through a Foreign Corrupt Practices Act (FCPA) investigation or enforcement action have been required to make such a change in the culture of how they do business. If your senior management is not committed to such change, the message will not make its way down to the troops in the field.

I thought that Kerger captured it well when she said, “Life is often about those moments — you have to be willing, every once in a while, to jump, and it’s absolutely terrifying. Our nature as humans is to not change. We get comfortable, and we don’t want to be pushed outside that comfort zone, whether it’s moving from a job that you know is not the right one or because it always feels so much easier to keep doing the same thing, even if it’s painful, rather than taking that leap.”

Kerger described her tools for making and then implementing, a culture shift. She begins with having a diverse leadership team. She said, “With the teams we build, we look for different skill sets and we look for people who bring different voices to the table. I know that’s now become very popular in theory, but that’s something I’ve always done. I always believe that the best projects are managed not by people who all think alike but who are all contributing something different.”

To effect this strategy, she also provided insights into how she has accomplished culture shifts. She has done so by pulling “teams together that have representation from every facet of the organization. So you’re aligning people together around shared projects and shared outcomes, and people get to know each other so then it’s not about us versus them. I think it’s good to have a blend of people that have been there for a while as well as new talent. I think tipping too far one way or another is always a problem.”

Another key leadership point is about communications. Of course listening to your team members is critical but Kerger took it to a broader context when she said, “Sharing information is also really important. In some organizations, leaders can go into their bunkers, and if people don’t get enough information, then they start making it up. I try not to shield people when the news isn’t always good, because they just need to know.”

Yet, at some point, leaders have to make a decision. Whether you are the CEO or the CCO, you will eventually be called upon to make a decision. Kerger said, “I like to get a lot of information before I make a decision, but I’m not afraid to make decisions. That comes back to the whole thing about being the C.E.O. You have to be able to move. People who always want all the information before they make a decision are disastrous C.E.O.s. You’re never going to have all the information.”

Kerger also had some interesting thoughts on hiring which can certainly be useful to the CCO. First is that she looks for people who are intellectually curious, in addition to a passion about the work of PBS. She wants people to have a “fire” for working in the public media. How many CCO’s consider the passion of those working in the compliance function? Many compliance professionals are passionate about doing the work of anti-corruption compliance because it is such a worthwhile endeavor, particularly in the business context. I often say that compliance programs are business solutions to the legal problem of bribery and corruption. If you can tap into a person who has this passion, they can help bring a level of enthusiasm to your company that may not normally be seen.

Echoing the emphasis Kerger puts on disparate team members, she also looks “for people who are going to bring something to the table and who will work well collaboratively, but I don’t want a group of people that just tell me what I want to hear. I just want them to tell me what I need to hear. And so I want people that are going to be comfortable doing that.” Finally, she wants someone who can be the “devil’s advocate, ensuring that “you don’t come up with consensus too fast.”” She ended with the following, “Even if you end up at the same outcome, you don’t want people walking out of the room saying, “Well, I wonder why we didn’t think of… ?””

I hope you have enjoyed and can use some of the concepts that Groysberg, Lee, Price and Cheng put forth. As a CCO, you can use some of the specific tactics of Kerger as well as the theoretical underpinnings of the authors of the HBR pieces.


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, 2018