This week is a return to one my favorite themes for every Chief Compliance Officer (CCO), compliance professional and compliance program: Sherlock Holmes. Over this week, I am considering themes from the short stories found in The Return of Sherlock Holmes to illustrate broader application to components of a best practices compliance program. I have used three primary resources in putting together this series: Maria Konnikova’s Mastermind (Konnikova); the online site shmoop.comand its contribution, The Return of Sherlock Holmes (shmoop); and finally the most seminal print work on the entire Holmes canon, the two-volume The New Annotated Sherlock Holmes (Klinger) edited with notes by Leslie. S. Klinger. Today, I consider the theme of mentoring in compliance.

Shmoop tackles head on the issue of admiration in the Holmes canon. They state, “Aside from being the world’s best sidekick, Watson is definitely the president of the Sherlock Holmes fan club. Watson admires Holmes so much that he basically devotes his entire life to Holmes. In fact, Watson almost doesn’t exist outside of Holmes. But not all types of admiration are taken to such extremes in these stories. Holmes is universally admired, and we see signs of hero-worship in Stanley Hopkins, Inspector Martin of the “Dancing Men” case, and even Inspector Lestrade on occasion. Holmes himself rarely admires anyone, except for a small number of clever nemeses. People often seem to bore Holmes. Neither Watson nor Holmes can see past Holmes’s awesomeness at times, but Watson’s admiration isn’t totally blind. He definitely expresses annoyance with Holmes on occasion. Admiration can be a positive emotion, but it’s often a source of blindness in these stories.” I believe Watson’s lack of blindness (at times) can be used to consider how a Chief Compliance Officer (CCO) should mentor.

In the story The Adventure of the Six Napoleons, Inspector Lestrade says to Holmes, “Well,” said Lestrade, “I’ve seen you handle a good many cases, Mr. Holmes, but I don’t know that I ever knew a more workmanlike one than that. We’re not jealous of you at Scotland Yard. No sir, we are very proud of you, and if you come down to-morrow, there’s not a man […] who wouldn’t be glad to shake your hand.” This comment provides insights into how Holmes is viewed by other law enforcement officers; Holmes is a sort of living legend and the other officers respect his skills.

The matter involved the theft of jewelry as Inspector Lestrade of Scotland Yard brings Holmes a seemingly trivial problem about a man who shatters plaster busts of Napoleon. One was shattered in Morse Hudson’s shop, and two others, sold by Hudson to a Dr. Barnicot, were smashed after the doctor’s house and branch office had been burgled. Nothing else was taken in any of the break-ins. It turns out that the thief had stolen several pieces of jewelry and then hid them in the Napoleonic busts. The thief, having been released from prison on an unrelated offense, was tracking down the busts in which he had placed the jewels for hiding, breaking them open and reclaiming his purloined property.

What are some of the ways that you might mentor a younger or less senior compliance professional? I think there are several ways suggested by Conan Doyle as epitomized by the statement by Lestrade and his relationship with Holmes and Watson. CCOs and seasoned compliance professionals tend to be passionate about compliance even if (like myself) they have a legal background and came to compliance from a corporate legal department. You should work to transmit that passion to others you are mentoring. In today’s hyper-transparent world of reputational risk, that passion can stand out as a differentiator. As with Holmes’ investigation into the destruction of the Napoleon busts, it is integration of the understanding of compliance into your company with all its various components. It is not simply the crossing of siloed boundaries but understanding the differences in business units, corporate functions and even geographic locations that can bring this broad sense of context.

As compliance professionals, transmit the ability to see not only the technical details but also the big picture of compliance. Introduce your mentees to others in your organization, so that they can be exposed to different leadership styles and see how such leadership styles work in various areas and with different constituencies. Encourage mentees to have a powerful sense of compliance community by encouraging cultivation in personal and professional networks. Any chance to participate in such an opportunity should be accepted.

Beyond passion, help them to develop purpose around careers in compliance. This can be aided through reflection, introspection and ability to change as a leader. Moreover, rather than influencing others through individual speeches or stories, the everyday connections between a compliance professional’s sense of purpose and the compliance vision can work to form an indelible impression about the importance of compliance to an organization. This is Louis Sapirman’s 360-degees of compliance in action.

If you are mentoring a compliance professional, you probably have a next generation mindset. But it is equally important that you communicate that to your mentee as it is certainly important that each generation of compliance leaders be fit for the future and be committed to continuous improvement going forward. Pass it forward.

By using these steps, a successful enterprise leader, a CCO or compliance practitioner can bring greater corporate wide presence to the compliance function. Moreover, by using them as guideposts for mentoring, you will make compliance a part of the business process as it becomes second nature and a recognized part of any business transaction. As you communicate to those under you to develop better relationships and how to mobilize compliance for the greater good, it will have the direct benefit of allowing you as the mentor to deliver more value for the company. It does not get much better than that.

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, 2018

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