Julie Adams died over the weekend. Most probably only true fans of the Universal classic monster movie oeuvre will recognize her name as the worthy successor to Fay Wray and Evelyn Ankers as the love interest/damsel in distress in The Creature from the Black Lagoon. While The Creature from the Black Lagoon came after the end of the final Frankenstein and Dracula movies from the 1940s, it is now recognized a cult classic, with Gill-Man (The Creature) joining the pantheon of Universal’s legendary monsters alongside Frankenstein, Dracula, The Wolf Man and The Mummy. It spawned the sequels Revenge of the Creature and The Creature Walks Among Us. It also informs today’s topic of moving compliance innovation forward.
Chris Koseluk, writing in the Hollywood Reporter, said, “Conceived as an underwater version of Beauty and the Beast, it featured a mythical sea monster dubbed “Gill-Man.” Played by Ben Chapman [the land scenes] and Ricou Browning [swimming in the underwater scenes], the creature menaced a scientific expedition to the Amazon. Richard Carlson, Richard Denning, Antonio Moreno, Nestor Paiva and Whit Bissell were cast as researchers…I thought, ‘What the hay! It might be fun.’ And of course, indeed it was. It was a great pleasure to do the picture.” A young Guillermo del Toro was a fan and years later used the movie as inspiration for The Shape of Water.”
I thought about The Creature from the Black Lagoon in the context of how to move compliance innovation into the corporate pantheon of greater business process efficiency when I read a recent MIT Sloan Management Review article, entitled “Grow Faster By Changing Your Innovation Narrative”, by George S. Day and Gregory P. Shea. In the article they discussed their findings that organizations that sustain growth “faster than industry rivals articulate a coherent, compelling innovation narrative and rely on four powerful levers to make it a reality.” They posited four key levers for doing so which I believe would work well for a compliance function to sustain innovative growth within an organization and with its customer base, i.e. employees. I have adapted their piece for such an exercise.
The first lever is to invest in compliance talent. This starts at the top of the organization committing to have a best practices compliance program. It means both head count and financial resources should go into the compliance function. Most interestingly, this mirrors the Department of Justice (DOJ) requirement articulated in the 2017 FCPA Corporate Enforcement Policy for the following: “The resources the company has dedicated to compliance; The quality and experience of the personnel involved in compliance, such that they can understand and identify the transactions and activities that pose a potential risk; The authority and independence of the compliance function and the availability of compliance expertise to the board”.
But investing in talent is more than simply throwing money at the compliance function. It is really investingin your compliance personnel. This means giving them training in a wide variety of corporate skills that will facilitate their work of and in compliance. This will have greater benefit for the organization as the authors related one person told them “You are not just hiring and developing innovation talent — this is a great training ground for senior jobs.”
The second lever is encouraging prudent risk taking. While this may initially sound antithetical to the role of a compliance professional, you should never forget that compliance does not exist to be the Land of No, populated by Dr. No. It is not the Land of Business (non) Development. For the same reason you have brakes on a car, to drive fast, not to slow down; compliance should be there to allow the business to more fully manage the risk that it needs to take to be successful. The more nimble and agile your company can be to manage its risk portfolio, the quicker it will be able to respond to market opportunities.
The third lever is to adopt a customer centric process. While this would seem obvious to every business-person, it is generally viewed negatively by those who advocate a compliance function as an extension of a corporate legal function, simply there to comply with a regulatory or legal framework and there to protect the company. The authors quoted Jeff Bezos in their piece for the following, “Rather than ask what we are good at and what else can we do with that skill, you ask, Who are our customers? What do they need? And then you say we’re going to give that to them regardless of whether we currently have the skills to do so, and we will learn those skills….”
Part of this is being nimble but another part of it is understanding what business you are in, how your organization is accomplishing it and, most importantly, where the business is going. Compliance should work to not only see where the business is going but how the compliance process can be made more efficient to positively impact the organization. Yet another way to think about this topic is by considering “What is possible.” As a compliance practitioner, you are only limited by your imagination.
Finally, the fourth lever is “along metrics and incentives with innovation activity.” Here you should work to present senior management solid analytics. These include metrics related to “nearer-term results, or “input” measures, such as process effectiveness, leadership commitment, or competency development.” The authors believe that input measures are what growth leaders emphasize in their dashboards. These metrics reveal a variety of insights, such as loose screening processes that leave poor ideas in the pipeline for too long, sloppy development processes that cause delays in hitting project stage gates, and poor product quality that requires recycling innovations back through the development stage.
The bottom line is that senior management is well-versed in the need for innovative and effective compliance. By using these four levers, a compliance practitioner can help senior managers to focus the organizations compliance efforts. The authors conclude by stating, “A growth-affirming innovation narrative and the four levers that make it manifest within a company can help leaders focus and prioritize their innovation efforts. The process of identifying and articulating the narrative is essential to understanding the culture of innovation within a company and envisioning what it can achieve. The levers bring that narrative to life. Without them, organic growth leadership in any industry is a hit-or-miss endeavor.”
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© Thomas R. Fox, 2019