Compliance and the Culture Challenge
The 17th century philosopher Thomas Hobbes believed that, without appropriate social controls, life would be “nasty, brutish and short”. This rather dim view of humanity pervades much modern compliance practice. In a nutshell, the assumption is that people will do the wrong thing and the job of compliance departments is to prevent wrong-doing and if we can’t prevent it, we need to catch and punish the wrong-doers.*
A consequence of this approach is that companies have tended to focus on rules, systems and infrastructure for their compliance programmes. This has the benefit of driving a comprehensive audit trail allowing companies to demonstrate that they are doing everything possible to identify and address unethical behaviour. But where is the evidence that this approach is actually driving compliant behaviour in the practice?
Times have changed and, increasingly, compliance professionals are seeking real returns on their investment in compliance programmes, not just in terms of boxes ticked but also in terms of real risk mitigation through changed behaviour.
People and companies are complex and nuanced. To drive compliant behaviour in the workplace I’d argue we need to understand and address the personal and cultural factors that can lead to resistance to compliance controls and messages. We also need to understand and influence the prevailing ethical culture of the whole organisation. Then we can design strategies and approaches to address them.
While infrastructure and systems matter, real and lasting change can only come from a more sophisticated appreciation of the role of human psychology and organizational culture. And this won’t be achieved if we still apply an outdated approach.
Join @KirstenListon and me at #SCCEecei in March to explore these issues and identify practical steps for compliance teams to take to influence the ethical culture of their organisations. We’ll address:
- What motivates employees to do the right, and the wrong, thing?
- How ethical culture is determined
- What compliance professionals can do to build an ethical culture
*For an interesting and more in-depth read on the philosophical underpinnings of approaches to compliance, @Carsten Tams published a fascinating article recently which you can read here.