World Series travel day so no scores to report. However, today I conclude my exploration of some of the films of Val Lewton during his tenure at RKO. Given the trajectory of horror films from the ‘30s and ‘40s, most particularly the Universal classics of Frankenstein, Dracula, The Mummy, The Wolfman and The Invisible Man; Lewton took things in a very different direction. As I have previously noted, the pictures he produced were much more psychological, with the terror occurring largely off-screen, left to the viewers imagination. I find that in many ways, Lewton presaged such films as Halloween, Jason, Nightmare on Elm Street and Friday the 13th in terms of atmospherics, although certainly not in terms of gore.

One of the best examples is the 1945 film, Isle of the Dead. In this movie the horror is a superstitious belief in a vorvolaka, a malevolent force in human form. Lewton once again brings back Boris Karloff to star in an eerie and creepy film where people living on what was thought to a desolated island die off suddenly. The island itself is properly evil and haunted as it the final burial place of victims of the Balkans War of 1912. A doctor on the island believes it is a septicemic plague which causes the deaths but an old Greek woman believes it to be a vorvolaka, in the guise of the red and rosy servant girl living in their midst.

The doctor believes that the plague may be eradicated in one day if the hot, dry sirocco winds arrive to the island. Eventually the sirocco winds do arrive and the plague is eradicated. Yet by then Karloff’s character as well as several others have gone made and either killed each other or killed themselves. The black and white filming allows terrific use of light and shadows. The tension in the movie is so great, Martin Scorsese has called Isle of the Dead, one of the Top Ten horror movies of all time.

I offer this final entrant in my 2019 October HorrorFest series as an introduction into the concept of scoping the role of your Chief Compliance Officer. What should a company do when it desires to hire a CCO? To find out, I visited with Maurice Gilbert, Founder of Conselium Partners LP, one of the country’s top compliance-focused executive recruiting firms. Gilbert believes that it behooves any company to find the right CCO or compliance practitioner for the right position. To do so, a company needs to fully understand and appreciate what it needs from such a position going forward. Unfortunately, many companies do not have this insight at the beginning of the recruitment process.

The process often begins with the company supplied job description, which Gilbert noted is “typically a legacy of various things that are not even updated. It’s a hodgepodge of things that maybe began a few years ago, but it needs to be updated to reflect what’s going on in the company at that particular moment. You have certain business risks. You have certain regulatory risks. You need to be attentive to those risks so that you could build your profile about what those risks need to be addressed presently.” Moreover, “what you’re going to get in a company job description is just a litany of things that actually could be quite disjointed and may not necessarily make sense for what you’re going to be asking the person to do.”

Gilbert brings the key company stakeholders into an initial meeting to help them understand the process. Obviously, this will include HR and others involved in the hiring process for the company. Gilbert gets them to rethink their approach to focus on what they will ask the new hire to accomplish because typically there is a disconnect between what the company thinks it needs and what it really needs.

The next step is developing an appropriate job profile. Gilbert asks the key stakeholders to give him a list of four things they would like the new hire to accomplish in the first year of employment. By limiting to this to four, Gilbert not only ends unrealistic expectations but helps winnow down the inevitable laundry list of wanting the professional to accomplish 30 things within their first year, many of which are inconceivable. “They must be done in the course of several years. When we listen to the response, we are counseling our client as to whether that makes sense or if that’s an unreasonable, let’s say, expectation.”

Gilbert gave an example of a recent search he headed for a client. One of the things he was able to develop at this initial meeting was that the company wanted the CCO “to spend the first two, three months evaluating her staff, to see if she has the appropriate team in place for the rest of the journey. By the way, she’s traveling all over the world doing just that. Evaluating her staff.” However, that task alone could take several months. The company also wanted the CCO to perform a comprehensive risk assessment immediately upon starting the position. It is simply not realistic to expect such disparate and time-consuming tasks to be performed so quickly, all the while the new CCO would be expected to travel to company locations across the globe.

Another important issue in this initial meeting is the professional growth opportunities that the company will present to any candidate. Gilbert explained that this is something companies do not always appreciate in the hiring process. Yet, as he explained, a company is trying to get a seasoned executive to leave a position, so they need to have an attractive package ready to present. It is more than simply salary and benefits. Gilbert said, “we have to capture data such as, “What are career growth options once a person steps in and does a good job for three, whatever, years?” We should capture data. “What is the culture of the company? What is the culture of the compliance department? What are the hot buttons and the management strategy, if you will, of the hiring authority? How does that person like to interface with the individuals?”

A final query to the company is around the sourcing of candidates. Gilbert needs to know if there are any particular competitors, or companies, which the client feels are out of bounds for sourcing candidates from and before he leaves the meeting, he needs to know the companies that his client does not want Conselium to recruit from going forward.

These points are quite illuminating for several reasons. First, a company must be clear on what it wants the new CCO to accomplish and to thoroughly consider what it would need to commit to in terms of resources to have these goals accomplished. Second, the communications flow facilitated learning on the part of both parties. (For the client, this was to have a realistic expectation of the new role. For Gilbert, it was to help develop an appropriate job profile.) It also demonstrated the collaborative nature of the relationship. By engaging in this process, Gilbert can move from simply a third-party executive search firm to a trusted advisor to the client. Moreover, by having such a relationship, Gilbert can deliver a much more focused and valuable service beyond the typical generalist experience available inside a corporation in the hiring process.

From these discussions, Gilbert develops a job profile and presents it to the company to have them sign off on not only the package of what they are looking for in a candidate, but also the package they will be willing to present. Gilbert related that through the capture of an agreement with these points, he is ready to begin the next step, which is to tell the compelling story about the job position on behalf of his client.

I hope you have enjoyed reviewing some of the old classic horror films from the 1940s. It certainly has been a joy for me to rewatch them this October to help prepare the year’s October HorrorFest series. Now get ready for all the ghouls and gobblins of Halloween.

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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