Earlier this week, both Matt Kelly and I explored the issue of complexity and compliance and how to deal with this in your compliance program, these posts were centered around the New York Times(NYT) report on the miss-steps of Boeing that caused or contributed to the 737 Max disasters. The posts can be viewed here, Fox: “Boeing and More Compliance Lessons Learned: Silos, Risks and Training”; Kelly: “Another Lesson from Boeing: Silos”. We also took a deep dive into it on this week’s episode of Compliance into the Weeds. I was therefore extremely gratified to see an article in this month’s Harvard Business Review (HBR), entitled “Cross-Silo Leadership”, by Tiziana Casciaro, Amy C. Edmondson and Sujin Jang.

One of the key reasons for the Boeing design failure was the siloed nature of the entire design, creation, training, regulatory and implementation team for the safety feature, the failed Maneuvering Characteristics Augmentation System (MCAS). The over-riding theme was the number of compliance miss-steps that led to the disaster. While the siloed nature of Boeing’s process led to a literal number of very small steps which contributed to the final disaster, it demonstrated to me even more clearly why compliance must not only have a seat the table but also be embedded throughout your organization.

Just as the siloed nature caused the pilots to not know what the engineers were designing to the software folks not appreciating how their changes were communicated to the employees who were responsible for assessing their safety impact to those tasked with obtaining regulatory approvals. The clear lesson for a Chief Compliance Officer (CCO) is that you must have visibility over your corporate operations to see how they all fit together. The answer is through looking horizontally; in teamwork, relationship, product design/creation and, most importantly, in operationalizing compliance.

The HBR authors noted, “Leaders need to help people develop the capacity to overcome these challenges on both individual and organizational levels. That means providing training in and support for four practices that enable effective interface work.” I have adapted their four practices for the compliance practitioner.

  1. Develop and Deploy Cultural Brokers

Most companies have employees who already excel at what the authors term “interface collaboration”. These employees have “experiences and relationships that span multiple sectors, functions, or domains and informally serve as links between them. We call these people cultural brokers.” Significantly, these cultural brokers promote cross-boundary work in one of two ways: by acting as a bridge or as an adhesive.

 The authors further noted, “A bridge offers himself as a go-between, allowing people in different functions or geographies to collaborate with minimal disruption to their day-to-day routine. Bridges are most effective when they have considerable knowledge of both sides and can figure out what each one needs.” They defined an adhesive as bringing “people together and help build mutual understanding and lasting relationships. Adhesives facilitate collaboration by vouching for people and helping them decipher one another’s language. Unlike bridges, adhesives develop others’ capacity to work across a boundary in the future without their assistance.”

  1. Encourage People to Ask the Right Questions

I found this next practice quite interesting. While the need for listening is well-recognized as a leadership tool, here the authors focus on the ability to ask questions as a key for horizontal silo breaking or what they termed “the value of inquisitiveness in boundary-crossing work”. Moreover, demonstrating this ability had the added benefit of persons identified with this skill, high levels of curiosity, “were more likely to build networks that spanned disconnected parts of the company.” But for the CCO it is more than finding people who will ask questions. It is also about creating processes to “help create an organization where it’s psychologically safe to ask questions.”

  1. Get People to See the World Through Others’ Eyes

As a CCO, you should do encourage “employees to be curious about different groups and ask questions about their thinking and practices; they should also urge their people to actively consider others’ points of view. People from different organizational groups don’t see things the same way.” This will be true in any multi-national organization subject to the Foreign Corrupt Practices Act (FCPA). This goes far beyond the simple prescription to have your Code of Conduct and policies and procedures translated into local languages, it means finding out what your employees think and believe and why they do so.

The authors believe, “while most people are capable of taking others’ perspectives, they are rarely motivated to do so. Leaders can provide some motivation by emphasizing to their teams how much the integration of diverse expertise enhances new value creation.” They suggest a couple of techniques to help in this practice. The first is to organize “cross-silo dialogues” where there are “cross-silo discussions that help employees see the world through the eyes of colleagues in other parts of the company. The goal is to get everyone to share knowledge and work on synthesizing that diverse input into new solutions.” The second is to hire for employees with different perspectives “by bringing on board people who relate to and sympathize with the feelings, thoughts, and attitudes of others.”

  1. Broaden Your Employees’ Vision

The NYT article made it clear that Boeing unwittingly encouraged its employees not to look “beyond their own immediate environment, such as their function or business unit, and as a result miss out on potential insights employees could get if they scanned more-distant networks.” As a CCO or other business leader, you need to work to change this attitude. The authors have two suggestions in this area. First, bring employees from diverse groups together on initiatives and projects. Second, urge your team and other employees to explore distant networks, by tapping into expertise outside the company and even outside the industry.

The authors noted, “In today’s economy everyone knows that finding new ways to combine an organization’s diverse knowledge is a winning strategy for creating lasting value.” But it is equally important to do so to prevent the type of culture which permeated Boeing. It appears that everyone involved in the MACS system design did their siloed job. Yet the end result was catastrophic failure with multiple loss of life. This needs to become part of the cultural DNA of your organization. The authors concluded by stating, “Over time these practices—none of which require advanced degrees or deep technical smarts—dissolve the barriers that make boundary-crossing work so difficult. When leaders create conditions that encourage and support these practices, collaboration across the interface will ultimately become second nature.”

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, 2019

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