Compliance and social media influencers

Influencer marketing has become a major trend in the advertising industry with the increasing dominance of social media and blog networks in the media landscape. With influencer marketing, brands and their advertising agencies identify the individuals to whom certain demographic groups look to for suggestions on trends or products and services to purchase. These individuals, referred to as “influencers,” then share or produce editorial content for their followers (the people who like or connect to them on social media networks) or engage in the brand’s marketing activities.

Through these sorts of campaigns, both the brands and the influencers hope to gain a non-traditional advantage in appealing to a wider audience. From the brand perspective, they get creative and incredibly targeted content that is produced on a bespoke basis for very specific consumers who are already engaged and interested in the channel through which the content is shared. Through the detailed metrics that are abundantly available via social media and blogs, advertisers can determine which campaigns were successful in spurring either interest or actual sales. From the influencer perspective, they get opportunities to generate paid content and engage with their followers and fans in a novel way. Relationships with brands can be very lucrative for influencers, especially if they become long-term, and can drive significant, much-desired traffic for blogs and social media posts that brings attention to other content the influencer has to offer.

From the above, it is evident that along with all the opportunity comes a complex set of interests which may end up in conflict or give rise to concerns about business practices and accuracy of representations and disclosures. For influencers in particular, blurring the line between the position a follower or a fan, which is even on some networks referred to colloquially as a “friend,” and the position of a customer or a referral, complicates an informal relationship where few duties are owed. Instead, these interactions can occasionally be viewed as a commercial relationship where much more responsibility exists and can be potentially breached.

  • In the United States, the Federal Trade Commission (FTC) is one of those regulators who is contemplating stronger restraints in the practices of influencer marketing. The main area of the FTC’s concern centers on disclosure of the relationships between brands and blogger influencers. Without full, clear disclosures, consumers cannot make reliable, informed choices about purchases they may be influenced to make due to influencer marketing content. The FTC hopes to protect customers from being misled or ripped off entirely by influencer marketing that is targeted to them without providing them with the necessary disclosures for them to make ethical and financially-wise decisions. The FTC has already informed influencers and advertisers that disclosure of relationships between them must be “clear and conspicuous,” with posts that paid promotions clearly indicated as such so that they are not lost within the influencer’s unpaid content that engaging with would not lead to a directly-linked commercial interaction. These regulations have been around for some time, but the extra enthusiasm for enforcing them protectively will have a much bigger impact on the market going forward: Regulating influencers: What retailers need to know about the regulatory crackdown
  • The SEC also has influencer marketing on its regulatory enforcement docket. This is an interesting clash of social media advertising etiquette and investor protection priorities. Companies offering trading of cryptocurrencies have begun to rely on celebrities for endorsements. Much of influencer marketing is done in “testimonial” style, so this medium lends well to a celebrity sharing his or her preferences with thousands or millions of followers. When that preference is for a cryptocurrency investment, however, the endorsement may run afoul of proper disclosure expectations. These regulatory expectations for cryptocurrencies are still evolving, as the market for initial coin offerings (ICOs) is in its infancy still and nearly everything that happens with cryptocurrencies is new, with its impact on banking, the markets, and investors unproven as of yet. Central banks and regulators have taken wildly different approaches in different countries to handling demand for and developments in cryptocurrencies. In the US, this approach has been cautious and restrained, but one area in which the supervisors have not been quiet has been to protect potential investors from advertisements without appropriate disclosures: SEC warns celebrities over endorsing ICOs without proper disclosure
  • Brands and influencers aren’t the only ones who may need to meet a higher disclosure standard when it comes to advertisements that aren’t immediately identifiable as such. Hidden marketing on social media sites as just as insidious as the political advertising that has received so much attention in the press recently. As Congress pushes social media platforms like Facebook to make clearer disclosures about and take more monitoring and control responsibility for the advertisements that appear on their sites, the need to build in protections against deceptive actions by marketers and their partners is urgent as well: It’s not just Facebook’s Russian ads: Hidden advertising is pervasive and growing
  • Social media compliance enforcement will be a major priority for the FTC in this regulatory environment. It should be expected that even within regulatory rollbacks in other areas, the FTC will continue to pay attention to possible non-compliant social media posts and advertisers and their related influencers could be subject to formal enforcement actions. Compared to some other industries like banking or pharmaceuticals, advertising agencies are subject to a relatively sparse supervisory agenda. This light regulatory touch may change dramatically if the FTC chooses to extend and entrench investigation and enforcement efforts on influencer marketing. This is worrying for the influencers as well, who are even less likely than advertising agencies or marketing divisions of brands to have fully-formed compliance programs and to be ready to have the record-keeping and other regulatory controls they may need in place and up to speed: How to Comply with FTC Social Media ‘Influencer’ Rules
  • For more on influencer marketing and the way that brands, advertisers, and influencers may use it to spread content in the future, check out this 2018 forecast for possible trends in the practice, which will in turn dictate the ensuing regulatory priorities, from Forbes: The Influencer Marketing Trends That Will Dominate 2018

Given these potential developments and risks, it is definitely not premature to direct appropriate and pro-active compliance attention to the cultivation and use of influencer marketing networks. Regulatory and supervisory entities are already starting to consider cracking down on various marketing activities in this sphere, and enforcement of disclosure and reporting standards will become robust and should be aided by proper control frameworks.

 

7 Habits for compliance professionals

Stephen R. Covey was one of the most prominent authors of leadership, self-improvement, and motivational books and speeches of the 20th century. Though the businessman, author, educator, and speaker passed away in 2012, his well-known writings are still influential and insightful for the current generation of managers, students, and thinkers. The teachings from Covey’s books can be applied in many fields of life – business, family, religion, and community, lending heavily to his continued popularity with a wide variety of people. Not simply positioned as self-help, Covey emphasized ethics and distinct definitions of both values and principles, as separate concepts that independently influence people’s behaviors and decision-making.

Due to these emphases, Covey’s writing is specifically interesting and useful for compliance professionals looking for a novel way to approach imbedding into a corporate culture both individual values – which one could see as ethics or morality – and organizational principles – which one could see as compliance program requirements and goals. Covey’s teachings often touch upon the value of inner success, rejecting external competitive measures as the true sign of achievement in favor of emphasizing personal mission statements and progressive goal-setting to allow an individual or an organization to go from immature dependence, through self-sufficient independence, into the higher state of functioning interdependence with others. This strategic vision has a high affinity with the sort of planning compliance officers must do to encourage a successful culture of compliance.

Arguably, Covey’s best-known book is the worldwide best-seller The 7 Habits of Highly Effective People. This book is not only a worldwide best-seller that gains new fans every year for its simple and timeless insights on how to work toward, achieve, and sustain inner success, but it is also the Covey book which is most applicable for compliance professionals to study and take into consideration in the course of their work.

Taken individually, each of the 7 Habits endorses values and principles and encourages conduct in support of those, which are useful for compliance risk awareness both in planning program priorities by the compliance officer as well as encouraging awareness and fostering integrity for individuals and organizations.

Steven R. Covey’s famous 7 Habits, annotated with suggestions for their applicability to corporate compliance and ethics programs, are as follows:

  1. Be Proactive – This is the first of three Habits that focus on maturing from dependence to independence, a process also referred to by Covey as self-mastery. This Habit introduces the concepts of Circle of Influence, one’s effective community – in a business perspective, partners, stakeholders, and clients or served parties – and Circle of Concern, where problems happen and dysfunction or distrust can stymy success and achievement.
  2. Begin with the End in Mind – Simply put, this Habit calls upon individuals and organizations to be devoted planners. Once the plan is set, apply with dedication to following it, in on-going and careful review of its efficacy and currency. Planning is a fundamental component of any successful compliance program. Setting goals and priorities for the program is necessary to encourage informed business buy-in and checking these goals and priorities on a continuous basis helps to keep them grounded in reality and responsive to evolving business and regulatory demands.
  3. Put First Things First – This Habit identifies the difference between leadership and management, a crucial dichotomy for the encouragement of both ethical leadership and adequate supervision, which are equally necessary in order to model conduct expectations and ensure progress in one’s mission. Covey says that leadership in society requires personal vision and for the individual to embrace the importance of character ethic, or internal personal qualities such as ethics, honesty, and loyalty, rather than personality ethic, or external personal qualities such as popularity or other short-term human interaction traits.
  4. Think WinWin – This is the first of three Habits that focus on interdependence, offering tips for working with others. In a service function such as compliance, working together effectively to establish a consistent and open relationship-based approach to risk management is crucial. Likewise, it is important for individuals to appreciate the importance of interdependence also, to see that their individual actions are significant in the overall scheme of the compliance program and to appreciate the importance of accountability, driving them to discuss dilemmas and enhance understanding. Finally, from an organizational perspective interdependence is also very important, driving home the cultural significance of corporate social responsibility and even political engagement in establishing corporate values and creating an identity and purpose in society.
  5. See First to Understand, Then to be Understood – This Habit focuses on the importance of listening for genuine understanding in order to build trust and promote personal credibility. Of particular importance are the Greek philosophy concepts of Ethos, the trust individuals inspire or in Covey’s words their Emotional Bank Accounts; Pathos, aligning and communicating with others and their own emotional trust; and Logos, the reasoning that must be included in communicating with and considering the trustworthiness of others, while projecting your own. Check back in the future for an blog post dedicated to the important concept of Emotional Bank Accounts.
  6. Synergize – This Habit reinforces the key interdependent competency of teamwork. Set goals together and achieve and maintain them together as well. In compliance terms, establishing trust and transparency as key values requires a cooperative commitment to supporting these individual values in the organizational principles that are established, be it via a corporate mission statement or through business strategy and growth plans.
  7. Sharpen the Saw – This final Habit focuses on personal and interpersonal continuous improvement. Balance is key to contended success in both life and business; no achievement attained with disrespect for resources it requires can be sustainable. In order to be truly successful, renewal and sustainability are the most important priorities. Continuous improvement for a compliance program or a company’s corporate values requires continuing risk re-assessments and a rolling plan for how to implement and refine compliance planning and communication.

For an in-depth look at Stephen R. Covey’s work and legacy, check out this official website maintained by the Covey Family. And for an entertaining take on the book, watch this animated book review of The 7 Habits of Highly Effective People.

Round-up on bioethics in medicine

Bioethics is a field of ethical thought and theory which focuses its debate on the relationship between society and biological sciences. These two sets of interests intersect and collide very frequently in medicine, where the impact of scientific advancement on people can be truly a life or death matter. Researchers, doctors, hospital organizations, medical service and product providers, and patients themselves all contend with bioethical dilemmas. With the ever-evolving advancement of AI and other technologies, medicine, like almost all areas of human life is being transformed and along with it, the ethical choices and challenges present are changing too.

  • As previously discussed in this blog’s coverage of whistleblowers in the pharmaceutical industry, the sales and marketing of prescription drugs is a practice full of risks for fraud and misconduct. Pharmaceutical companies paying or otherwise influencing doctors to recommend and prescribe their products to their patients is ripe for conflicts of interest issues. Doctors who might prescribe medication for any reason other than the most appropriate treatment protocol and wellness outlook for their patients, to whom they owe a high standard of professional care, pose great risk of causing both intentional and negligent harm. The risk of this is exceptionally troublesome when the doctors have histories of fraud or misconduct.  Payments from pharmaceutical companies to doctors are legal and not unusual, but they are also certainly controversial and pose significant bioethical challenges to appropriate patient care. In this case, there is definitely a call for compliance controls and ethical decision-making incentives, in that the conduct not against any law or regulation but may certainly run afoul of society’s expectations or medical institutions’ business values:  Drugmaker paid doctors with problem records to promote its pill
  • Traditional Chinese medicine, which uses herbs, plant, and animal parts to make teas or soups, has been relied upon as a popular remedy for centuries. While the practices of clinics offering these ingredients and instructions for using them as cures have been largely unchanged all this time, in recent years technological innovation has reached even into these farthest corners of medical practice. Some of these old-fashioned recipes have gotten a modern variation, turning them from culinary creations to formulations for injectable drugs. The risk lies in the possibility that the patient taking the drug might have an adverse reaction, as the injectable versions of these drugs contain many different compounds, making diagnosing an allergy or contamination very difficult. As major companies enter this market estimated at $13 billion in sales value, doctors are prescribing drugs that are largely unregulated, untested, and unknown. This presents a huge regulatory challenge to ensure public safety and to set supervisory standards for prescription and administration of the drugs:  Patient Deaths Show Darker Side of Modern Chinese Medicine
  • Recently an elderly, unconscious patient showed up in Miami, Florida hospital with a shocking tattoo that read “DO NOT RESCUSCITATE.” Doctors and nurses found themselves struggling to resolve the ethical dilemma of determining their patient’s true desire for care and to what extent. In the state of Florida, an order to not resuscitate (DNR) is valid only if it is completed on an official form and printed on the designated yellow paper. This patient did end up having such a legal form, so when his condition deteriorated eventually, the valid DNR was honored. However, doctors did debate what reaction, if any, they owed to the tattoo and the patient’s evident choice to make his DNR wishes emphatically clear. The medical team in question here provided basic care, sought ethics advice, and got the support system of social workers involved to make a collaborative, respectful patient care plan. The question of what would motivate a patient to have such a tattoo, however, and the wide variety of medical and legal reactions it can provoke, presents an interesting bioethical dilemma in end-of-life care: What to Do When a Patient Has a ‘Do Not Resuscitate’ Tattoo
  • Continuing on this theme of patient care at the end of life, another compelling bioethical dilemma is in the provision of non-essential treatment in hospice. In this case, a patient wanted eye surgery to restore his vision for the last days of his life. He desired comfort, independence, and reconnection with his family before he died that being able to see again could uniquely give to him. Some care providers, however, would not find it acceptable to perform surgery on someone who would die only a few weeks later, incurring costs and risks to provide ultimately unnecessary treatment. The question of when and why to provide this sort of treatment to hospice patients has arguments for cost and efficiency on one side and dignity and compassion on the other: Should Eye Surgeons Fulfill A Dying Man’s Wish To See His Family?
  • During all surgeries and medical treatments, there is an ever-present risk that something could go wrong and the professionals performing the procedure will need to stray from the expected protocol. While this is done in the best interests of treatment success and preventing harm or even saving lives, these interventions present difficult challenges to consent and control. In the scenario of childbirth, these concerns are especially fraught: Doctors who ignore consent are traumatizing women during childbirth

The moral and ethical questions posed in the evolving practice of medicine are and will continue to be the subject of frequent popular debate. Medical care providers confront these issues in their work and standards for and expectations of patient care are impacted by decision-making on these bioethical dilemmas. To build upon the commentary here, check back on December 21 for a post on bioethics issues in scientific research.

Compliance and MLMs

Although multi-level marketing companies (MLMs) have been selling products and services via “distributor” networks for years, they have shot to prominence in the aftermath of the 2008 global financial crisis. In reaction to long-term unemployment or under-employment and systemic, structural changes to the labor market in many communities, non-traditional workforces such as the non-employee, commission-only participants in MLMs have become more common than ever before in the United States.

MLMs all determine their own compensation scheme and marketing and recruitment strategies, but they do share some similarities with the way they brand themselves and communicate. They operate in diverse industries, from nutrition and fitness/wellness to fashion apparel to jewelry to housewares, but they all are organized around a pyramid-shape commission system, where participants at the top recruit and make residual income from the participants below them on a sliding scale. These business also all rely heavily on worth of mouth marketing, both to sell the products or services on offer as well as to recruit new participants to fill out the levels of the pyramid.

Because of this operation style, MLM participants are expected to promote the products and the company itself very eagerly, often expressing the financial freedom and flexibility that the non-traditional working arrangement has granted them in unstable times and portraying the MLM company as a self-employment or entrepreneurship opportunity. These portrayals are particularly effective with the aid of social media and are prevalent in communities where social connection and employment consistency may be hard to achieve and sustain, such as stay-at-home parents, military spouses, or people who need to work from home for medical or personal reasons.

While some MLMs certainly do offer popular products and present an opportunity for participants to earn at least some income, studies have shown that most participants make no money from their involvement or even lose money due to sunken costs of inventory and personal products they buy and do not or cannot sell. Questions are rampant as to whether many MLMs are pyramid schemes, scams that purport to sell products or services but really just recruit members in order for them to recruit other members.   These schemes are often illegal and seen by many as immoral due to the misleading or even fraudulent representations made to participants to get them to spend money, join, and continue making investments.

  • As noted above, one root cause of the popularity of MLMs in the current economy is the struggle of many communities for economic opportunity post-financial crisis. Rural communities, for example, were especially hard-hit by the crisis and have not experienced a fully-realized economic recovery in the following years. To these individuals, joining an MLM appeals because it promises freedom for family time, quick income, and an “American dream” lifestyle that is otherwise far out of reach. This version of the MLM business model is laser-targeted to women in these rural areas who did not work before the financial crisis or don’t work now and seek economic freedom and community, as well as the allure of fun products such as nail decals or whimsically patterned leggings. These companies hawk a message of women’s empowerment and female entrepreneurialism matched with a do-it-yourself dream of financial success. Unfortunately, many of these people enter into these businesses by getting into debt and are never able to recoup their initial investment let alone make money for it that could justify the effort and hours spent. Most disconcertingly, many of the participants enter without any risk disclosure from the MLM company:  Multilevel-marketing companies like LuLaRoe are forcing people into debt and psychological crisis
  • This New Yorker piece goes into greater detail about the ways that MLMs play up the aspirational nature of their branding to recruit participants who join unaware of the attendant possible risks. In this case, companies such as DoTerra market aromatic oils to which all kinds of medicinal properties are ascribed without any regulatory or legal legitimacy to reinforce this. Participants in these MLMs often claim that their suffering from psychology, physical, and other medical problems have been almost miraculously addressed by using the products they are selling. The companies operate in a gray area of not giving medical advice but nonetheless suggesting that the products can help with health or lifestyle problems, creating an echo chamber where customers and participants assure themselves that they are both sick and able to be cured by buying expensive essential oils and other homeopathic, non-regulated products: How Essential Oils Became the Cure for Our Age of Anxiety 
  • Here’s yet another perspective on how female participants have been manipulated through MLM company marketing and social media to stake their financial well-being on unattainable goals of personal enfranchisement and economic success. In their efforts to reach toward these goals, participants often find themselves instead in over their heads, without proper training or sufficient expertise selling products that are not regulated, effective, or sometimes even safe:  How Women Making Men Rich Has Been Misbranded As Feminism
  • MLM participants aren’t only at danger of fraud, misrepresentation, and other risks from the companies for which they are sellers. In a commercial market run by independent sellers and conducted via person to person sales, often online and even on social media, sellers are vulnerable to disputes with customers. Buyers can be fraudulent or even predatory and sellers often find themselves out on both the product and their money. MLMs such as LuLaRoe often do not step in to intervene on behalf of their representatives, who have a consultancy relationship with the company and therefore are not afforded the same protections as employees might be. The style of selling is overwhelmingly casual, social marketing conducted via comments on pictures on social media or at parties, making direct salespeople especially susceptible to scammers:  Do MLMs Protect Their Online Sellers From Fraud?
  • Since 2012, hedge fund manager Bill Ackman has been embroiled in an ongoing dispute with Herbalife. Ackman has spent years shorting Herbalife in hopes that its stock price will be driven to zero by public and regulatory identification of the company of a pyramid scheme. Due at least in part to the publicity generated by Ackman and likeminded individuals, in 2016 Herbalife settled with the Federal Trade Commission to resolve their charges that the company had made deceptive disclosures to distributors who lost money. As part of the FTC settlement, Herbalife agreed to provide evidence that its products are being sold to actual customers and not just participants within the pyramid who are funding their own involvement and keeping the façade going to recruit new people underneath them. The standard this settlement sets for the MLM industry, should the FTC keep pace with investigation and enforcement priorities in this, could greatly complicate the way these companies operate: Herbalife Deal Poses Challenges For The Industry

To find out more about MLMs, how they have become so ubiquitous in today’s employment market, and the risks they pose to participants and the economy in general, check out the great piece from a 2016 episode of Last Week Tonight with John Oliver.

Fraud in sports: Marathon cheaters

This is the first of a five-part series discussing fraud in sports. This starts with today’s post which will discuss runners who have been publicly exposed as cheaters in marathons. Next Tuesday’s post will be about imposters and scammers in the world of thru-hiking, a popular endurance sport where people long-distance trail hike in areas like the Appalachian Trail in the Eastern United States or the Pacific Crest Trail which stretches from California to Washington. On Tuesday December 19, the third post will be about sports fraud via gambling, including betting by players and illicit investment schemes. The fourth post on December 26 will be about game fixing, such as the Black Sox Scandal in which several players on the Chicago White Sox conspired to throw the World Series. The fifth and final post, on January 2, will be about major doping scandals, including Lance Armstrong and allegations of systematic doping by the Russian Olympics delegation.

Marathon cheating is a phenomenon that has both fascinated and infuriated running commentators. In a community which is fixated on qualifying times, personal bests, and self-identifications as hobbyist or elite runners which can be separated by mere seconds of pace time, honesty about runner times and speeds is sacred.   In this context, runners who cut courses short, falsify results, or claim publicity for false achievements, undermine the most fundamental measures of success in the marathon running world.

  • In the 1980 Boston Marathon, Rosie Ruiz, a 26-year old New Yorker, finished first among the female runners with an impressive time of just over two hours and thirty minutes. In the face of her amazing accomplishment, Rosie was nonplussed and composed – probably because she cut the course and did not run the 26.2 miles. Ruiz had her medal revoked when other runners stated that they witnessed her running onto the course at mile 25. It turned out that she exited the marathon course near the beginning and took the subway there, where she re-entered and claimed a false victory. Upon investigation, it was discovered that Ruiz’s Boston qualification time, run in the 1979 New York Marathon (her only other marathon before), was fake also, achieved because Ruiz again cut most of the course by riding the subway to re-enter near the end. Ruiz’s fraud rocked the marathon running community, in which road racers had a strong honor code that they felt was pure and safe from cheating that had afflicted sports with equipment or environments that could be altered or adjusted for cheating: Backtalk; 20 Years Later, the Legend of Rosie Ruiz Endures
  • Kip Litton intended to be well-known far outside of his social circles in Clarkston, Michigan as a champion marathoner. However, he has gained notoriety for a different accomplishment in marathon running entirely: prolific misrepresentation of his results and of races run. As Litton shot to the head of the pack in a number of small marathons, his fellow runners became confused by and curious about his quick rise to the top. By investigating race photographs and triangulating his likely performance based upon verifiable race times and per mile paces from previous chip-timed runs, other runners discovered that Litton was falsifying his performance. He was able to pull off this fraud by strategically picking races where he could cut courses or claim to have run qualifying times without even participating at all. The evidence of Litton’s misconduct assembled by the amateur investigators is fascinating and pathological in its devotion to his fraud, even amid Litton’s disqualifications from various races after inconsistencies were pointed out to directors: Marathon Man 
  • Social media has provided a fertile environment for inventive marathon cheating. Legitimate runners who share photos showing their bibs, the identifying numbers that runners wear pinned to their chests or backs during the race, have had those photos stolen and used for bib replication. Runners then use the fake bibs to “bandit,” or run incognito and illicitly, at races. This could be to avoid paying registration fees, to falsify qualifying records, for a prank, or for a creative type of identity theft. As discussed above, the runner community is vigilantly self-policing, and the fascination with these bandits leads to far-reaching vigilante investigations and reporting to race administrators to “out” cheaters:  Inside the Weird World of Social Media Marathon Cheating 
  • The 2017 Mexico City Marathon was mired in scandal when almost 6,000 runners, nearly 20% of the field of 29,000 runner, were disqualified for cheating. Investigation showed that many runners missed timing mats. Others, however, blatantly cut the course, either by riding the subway (harkening back to Rosie Ruiz in New York in 1979 and Boston in 1980) or “bib mules,” runners who wear bibs intended for other runners who do not compete at all, in order to falsify their results (typically to post a qualifying time for Boston or another exclusive race). What exactly happened in Mexico City remains unclear, but it seems to have been a combination of opportunistic runners who took advantage of technological difficulties or shortcomings at the race, and runners cutting the course short by missing timing mats. Such a dramatic disqualification rate should lead the Mexico City organizers and indeed anyone who is behind setting up and administrating a major race event to take a deep look at their internal controls and ensure that future races are set up to diminish the possibilities for going off-course or bandit running:  What the Hell Happened at the Mexico City Marathon?
  • For runners who achieve their results legitimately, race day represents many months or even years of hard efforts brought to fruition. Therefore, for serious runners, cheating and falsifying results is a real insult to all of their work and cheapens the prestige they seek of a credible accomplishment. Therefore many marathon runners who are active in the online communities such as the LetsRun forums take their annoyance or offense at this perceived dishonesty to the next level, launching widespread investigations into uncovering and calling out impropriety. Many runners who do not cheat see those who have cut courses or faked times bragging online, promoting themselves via social media, and their outrage at these actions speaks to the philosophical morality of running. At its most elemental level, and despite the many data-driven external successes one can achieve in the sport, running is a pursuit of internal success, a battle within the self for endurance and accomplishment. Cheating hinders and harms this. People who investigate and call out cheaters hope that they are working as deterrents to runner dishonesty as well as acting as a sort of informal self-regulatory organization for the running community: How to Catch a Marathon Cheat  

For a lot more fascinating examples of and insight into marathon cheating, check out the site Marathon Investigation. Run by Derek Murphy, a business analyst, marathoner, and running fan, the site is a comprehensive survey of impropriety and cheating at marathons all over the world. It offers a really compelling look into the analytical and research aspects of investigating and tracking potential cheaters by using historical data, GPS records, published running times, maps, race photos, and much more publicly available data. For more about Murphy and his motivations and methods, read this profile.

Check back next week, Tuesday December 12, for the second post in this series of five, which will be about fraud in sports as illustrated by thru-hiking fakers and scammers.

Selected TED/TEDx talks on artificial intelligence

Artificial intelligence (AI) describes the cognitive function of machines through technology such as algorithms or other machine learning mechanisms. The very definition of AI places technological devices with this “artificial” knowledge in comparison to and opposition with humans possessing “natural” knowledge. This discipline within technology has been around for more than sixty years and in recent years, is gaining consistent enough momentum that many of its once outlandish ambitions – such as self-driving cars, for example – are current or imminent reality. As computing power advances exponentially and uses for and types of data are ever-growing, AI is becoming ubiquitous in the news of the newest and emerging technological innovations.

As AI sustains and draws on its now considerable basis of achievements to make even more advancements in research and development across many business sectors, ethical and existential dilemmas related to it become more prevalent as well. Returning to that initial dichotomy between artificial or machine intelligence and natural or human intelligence, the design ethics and morality of bestowing human-like thinking ability on devices and networks raise many philosophical questions. Certain uses of AI, such as for autonomous weapons, could even pose safety risks to humans if not developed and directed thoughtfully.

These questions can go on and on; practical ethics represents the attempt to navigate the broad social context of the workplace by reconciling professional rules with moral expectations and norms. This, again, is highly pertinent to a corporate compliance program, which seeks to encourage an business culture that respects legality, approaches business competitively yet thoughtfully, and also sets standards for employee and organizational integrity. It is imperative for compliance professionals to understand practical ethics and use dilemma sessions or open discussions with the businesses they advise in order to encourage a common comfort level with this sort of thinking throughout their organization.

The below TED/TEDx talks emphasize the connection between AI and human life, commonly invoking questions about bioethics, practical ethics, and morality.

  • Artificial intelligence: dream or nightmare? (Stefan Wess) – Stefan Wess, a computer scientist and entrepreneur, provides a helpful primer on the history and current state of artificial intelligence in the contemporary movement of machine education. Big Data, the Internet of Things, machine learning, speech recognition – all these technologies and AI-related topics are already part of daily life. But as this continues to develop, how will organizations and individuals interact with the technology? How should it best be controlled and is it even possible to do so? The many risk implications of AI must be considered as more advanced creations become stronger and closer to reality every day.

 

 

  • Can we build AI without losing control over it? (Sam Harris) – Neuroscientist and philosopher Sam Harris is well-known for his commentaries on the interaction of science, morality, and society. Advanced AI is no longer just theoretical stuff of science fiction and the very distant future. Superintelligent AI – completely autonomous, superhuman machines, devices, and networks – is very close to reality. Technologists, the organizations in which they work, and the communities for which they create must all be conscientious about the development of these technologies and the assessment of the risks they could pose. Contending with the potential problems that stem from creating this very advanced AI needs to be done now, in anticipation of the technology, not later – when it may no longer be possible to control what has been designed and brought to “life.”   Planning, careful control frameworks, and regulatory supervision that balances openly encouraging innovation with soberly considering safety and risk consequences are all necessary to conscientiously embark upon these amazing technological endeavors.

 

 

  • What happens when our computers get smarter than we are? (Nick Bostrom) – In the same vein as the previous talk, one of the consequences of extremely “smart” artificial intelligence is that machine learning could be just as smart as a human being’s knowledge – and then, of course, eventually overtake humans in intelligence. This is alarming because it suggests the potential that humans could introduce their own subservience or obsolescence via machines created to make machines smarter. Again, all participants in developing this technology, including the consumers to whom it is ultimately directed, need to consider their intentions in bestowing machines with thought and balance the various risks carefully. With the ability for independent thought may also come the capacity for judgment. Humans must make an effort to ensure the values of these smart machines are consistent with those of humanity, in order to safeguard the relevance and survival of human knowledge itself for the future.

 

 

  • The wonderful and terrifying implications of computers that can learn (Jeremy Howard) – The concept of deep learning enables humans to teach computers how to learn. Through this technique, computers can transform into vast stores of self-generating knowledge. Many people will likely be very surprised to learn how far along this technology is, empowering machines with abilities and knowledge that some might think is still within the realm of fantasy. Productivity gains in application of machine learning have the potential to be enormous as computers can be trained to invent, identify, and diagnose. Computers can learn through algorithms and their own compounding teaching to do so many tasks that will free humans to test the limits of current inventions and to extend human problem-solving far beyond where it already reaches. This is certain to change the face of human employment – already bots and androids are being used for assisting tasks in diverse fields from human resources recruiting to nursing patient care.   Again, the extension of these technologies must be carefully cultivated in order to neutralize the existential threats to human society and life that may be posed by unchecked autonomy of machines and artificial learning. The time to do this is now, as soon as possible – not once the machines already have these advanced capabilities with all the attendant risks.

 

 

  • What will future jobs look like? (Andrew McAfee) – Picking up on the theme of the changing nature of human employment as machines get smarter, Andrew McAfee draws on his academic and intellectual background as an economist to unpack what the impact on the labor market might be. The fear, of course, is that extremely human-like androids will take over the human workforce with their advanced machine intelligence, making humans mostly irrelevant and out of work. The more interesting discussion, however, is not whether androids will take away work from humans but how they may change the kinds of jobs that humans do. Considering and preparing for this reality, and educating both humans and machines accordingly, is imperative to do now.

 

 

Check back here in the future for continuing commentary on AI and its impact on human life and society, including technology and the ethics of knowledge acquisition, as well as more insights on specific AI innovations such as self-driving cars and machine learning.

Profiles of ethical leadership in sports coaching: Gregg Popovich

This is the fifth and final post in a month-long series profiling acclaimed sports coaches for their ethical leadership abilities. John Wooden, famed UCLA basketball coach, and his Pyramid of Success were the subject of the first post. The second post was about Johan Cruyff, world-famous Dutch footballer and international club manager, and the ethical leadership lessons of his 14 Rules. The third profile discussed Jim Valvano and his views about leadership and success as expressed in lines from his famous 1993 ESPY Awards speech. Last week’s post focused on Vince Lombardi, the NFL Hall of Fame coach, and values for ethical leaders from his famous motivational speeches.

Finally, today’s post will be about Gregg Popovich, an NBA coach who heads up the San Antonio Spurs and is well-known for his progressive and pro-active values, which often manifest in very public and political statements.

Before becoming an NBA coach, Gregg Popovich attended the United States Air Force Academy where he played basketball and majored in Soviet Studies. He served in the Air Force for five years before returning to the Academy to coach basketball there, followed by a stint as head coach at Division III Pomona-Pitzer and then assistant coach jobs in the NBA for the San Antonio Spurs and Golden State Warriors, before returning to take a general manager job with the Spurs in 1994.

Popovich is widely considered one of the most accomplished coaches in NBA history. He has been the coach of the San Antonio Spurs since 1996, making him the longest tenured active coach in not only the NBA but in all US major sports leagues. The competitive successes of the San Antonio Spurs under his stewardship are many – 20 consecutive winning seasons, five NBA championships, and more than 1,000 games won.

However, Popovich’s legacy as a winning basketball coach may be matched by his legacy as an outspoken and consistent leader on social justice issues – both in society as a whole and on the direct scale among his players. Popovich consistently uses his very visible platform to speak about inclusion, engagement, and accountability.

  • This 2007 profile of Popovich from Canada’s National Post hints at the values Popovich brings to his overall coaching vision. The profile notes that Popovich’s media profile was, at that time, lower than some other great coaches because he was not interested in self-promotion, nor did he have a singular “vision” for the team that was well-suited for branding and publicity purposes. Instead, he focused on building “strong, complicated” relationships with his players and emphasizing worldly knowledge and overall excellence alongside basketball fundamentals. This profile is especially interesting for the quote at its end, which at that time was posted in the hallway by the Spurs locker room, translated into the various languages the players on the team spoke: “When nothing seems to help, I go look at a stonecutter hammering away at his rock perhaps a hundred times without as much as a crack showing in it. Yet at the hundred-andfirst blow it will split in two and I know it was not that blow that did it but all that had gone before.” This view of success can only be espoused by a leader who sees the values and efforts of the organization as inseparable from those of the individual. This is a powerful and indeed empowering perspective on management as an activity and skill which serves the collective of the organization as well as each individual within it:  Popovich is a man of mystery
  • This 2013 round-up on Popovich centers on his interesting and complex personality and background, intended to fascinate basketball and sports fans. In most cases, these traits and experiences translate directly to his ethical leadership qualities as well, and the root is in Popovich’s personalized and compassionate approach to coaching individuals rather than just constructing offenses, defences, and plays in a vacuum. When he was general manager of the Spurs and the head coach wasn’t getting the job done, Popovich stepped up and put himself on the line, eventually hiring himself as head coach. He took tough decisions and made himself responsible for them, a behavior that embodies ethical leadership: An Ode to Gregg Popovich, the Most Interesting Man in the NBA
  • In 2014, Fortune included Popovich in its “The World’s 50 Greatest Leaders” feature. In this view, Popovich, portrayed as curmudgeonly and stoic, distinguishes his leadership by enabling his whole team, from the bench players to the superstars, to excel and achieve. His no-nonsense style focuses on character ethic, not personality ethic, which is the central value for promoting and sustaining individual integrity to then scale across the organization. Popovich’s leadership is special in this view because it is so relationship-focused, giving his players incentive to seek individual inner success, not just to please a coach or beat an opponent in a one-off, unsustainable fashion: Another victory for ‘Pop.’ Another show of leadership
  • Business Insider ran a 2016 piece on Popovich which again centered on his relationship-focused, individual-valuing coaching philosophy. His perspectives on rebounding from failure, organizational governance, and player development all fit within the broad strokes of ethical leadership. In particular, Popovich emphasizes that motivating players and resolving conflict is best accomplished through honesty and personal accountability. These is fundamental perspective for encouraging organizational and individual (employee, player, or otherwise) integrity. Again, character ethic is the most important, and this enables open communication and feed-forward development and problem-solving:  Gregg Popovich has a brilliant philosophy on handling players, and it exemplifies the Spurs’ unprecedented run of success
  • From 2017, this ESPN piece focuses on Popovich’s political engagement and public opposition to what he sees as immoral political behavior. However, the rationale for why Popovich feels so strongly about this and indeed why he feels that he has an ethical imperative to speak out loudly about it is very illustrative of his leadership views. The article shares an anecdote about a time that Popovich began a high-stakes film session by sharing his knowledge on a historical topic of personal importance to one of his players. Popovich creates an environment of inclusion on his team by making what is different between them, important and meaningful to all of them, by translating these lessons into leadership messages for all. This empathetic approach to leadership is an ultimate expression of integrity and engagement, two imperative ethical qualities in management. For the Spurs, recruiting based on diversity and then using that diversity as motivation leads to both market competition as well as organizational cohesion:  Why President Trump ignites Gregg Popovich

Hopefully this series of posts about sports coaches as ethical leaders has been entertaining and informative, lending a new perspective to management values in a different venue than the traditional corporate compliance environment. The concepts of inner success, character ethic, personal accountability, and purpose-driven life and work are all commonly endorsed by these ethical leaders as they guide their teams, which are major organizations in and of themselves, to competitive achievements with meaningful, sustainable motivations behind them.

How to make voluntary engagement with compliance values meaningful

A pure rules-based approach to compliance is direct and clear-cut, but by design lacks emotional or personal engagement. Following rules of all kinds – legal, community-based, household; practical, austere, illogical – is a social norm most humans are taught from their earliest memories. Despite this, many of them do not do it very well even with the best intentions, and still more never intend to attempt adherence.

To have any expectation that rules will be credible and inspire understanding and respect, there must be an authentic and compelling “why,” a purpose that people feels relates to them and calls for their commitment. Many laws are so deeply linked to societal expectations and taboos that the majority of people do not need to be persuaded to appreciate them – restrictions against pre-meditated murder, property theft, and abuse of animals for example. Those who remain unconvinced these acts should be prohibited and punished are not likely to view violating laws as something offensive or damaging either.

Sincere attempts to reach individuals who are antipathetic toward all rules, however few or rare they may actually be in society, with a rationale rooted in values are not likely to prevail. In general a values-based approach can be very powerful and evocative, but in order for it to hold personal appeal it must strike a difficult balance between universal relatability and individual accountability. All organizations should define their values and position their strategy and public branding within that set of principles, but this is delicate. If the values are too specific then they will be exclusionary rather than engaging, appealing only to a core group of true believers rather than attracting a wider audience. If the values are too broad, however, then they will be superficial and ring empty – again preventing individuals from attaching to them and being their standard bearers.

An especially effective tactic for bridging this gap is to make corporate values a living artifact which reflect the organization as it grows and changes along with business and society. In an ambitious and forward-looking organization, the profile and strategy will evolve and so should the outlook of what matters most in defining its purpose. Using a rules-based approach to provide both the floor and the roof for the terms of the corporate mission statement, values can fill the space between and invite everyone – employees, partners, stakeholders alike – inside.

There are many mechanisms through which corporate compliance programs can appeal to employees to make the connection between rules and values. Inspiring voluntary compliance, where employees feel aware of and responsible for the values of the compliance program and connect to them individually, adds weight to the mandatory compliance expected by the rules. Increasing the relatability of the requirements with principles behind them gives people incentive to sign on and go along with the compliance program. Compliance programs can aim to encourage ongoing employee adhesion to the organization’s values-based approach in the following ways, ranging from the lightest touch to the heaviest:

  • Nudges: Simply put, make it possible for employees to make ethical choices by expressing values that promote this and building decision-points into the processes they encounter in their working experiences which reflect those values. Business strategy should coincide with business values, and if it does not, then actions such as setting new standards client acceptance or exiting and reassessing product offerings or market participation are natural consequences of trying to bring the two together. In order for employees to make choices that reflect both individual and organizational integrity, the procedures and standards within which they work should facilitate and support this type of decision-making. Doing the right thing should always be accessible and indeed prompted.
  • Codes: While nudges make values implicit and leave the decision ultimately in the employee’s hands, in codes values are explicit and expectations for adherence to them are formalized. Codes can take a variety of formats, and in some industries regulatory requirements may dictate their scope and even content, but generally speaking, the more concise and accessible the better. Employees at all levels should be able to read, understand, and engage with the code, whether it dictates ethics, conduct, or both, and they should be able to retrieve, review, and ask questions about it whenever they want. A code document should be updated on an ad-hoc basis and reviewed regularly, and it should be seen as a living record of the specific values of the organization which underlie all other policies and procedures in place.
  • Attestations: Once a code is available, employees can be asked to attest to their compliance with it. This can take a very simple form, even just a one-liner of “I attest that I have been in compliance with the requirements set forth in the Code as of the below date.” This can be done once per year (or other regular period of choice) or on an ad-hoc basis. Asking an employee to attest to adherence prompts self-reflection and may also create a space for questions or dilemma discussions, which are important tools for ensuring awareness.
  • Warnings: Warnings may sound punitive, but in reality they can just be reminders. Unlike attestations, which look backwards and ask employees to self-assess based on their past behavior, warnings would accompany present choices or activities. For example, an expense claim form might include a statement on it reminding the submitter that the data on the form should be accurately and honestly reported, and that there are certain expenses which may not be reimbursable or permitted. Providing these warnings at the time the employee is going to take action that checks compliance values brings together all the previous methods – it provides a nudge, makes expectations explicit, and directly asks the employee to consider ethical obligations when making choices in the course of the task.
  • Oaths: Oaths take the most advanced step of ensuring that employees comply with the ethical and compliance expectations of their profession by asking that they voluntarily submit to discipline should they violate these. This submission is by taking an oath and signing it, typically with witnesses and even a level of formalization or ceremony in order to underscore the significance of the commitment and the seriousness of trespassing against it with future misconduct. A very interesting example of a professional oath is the Banker’s Oath in the Netherlands, which is intended to restore trust in the financial sector and banks specifically by requiring that every Dutch employee take an oath to comply with uniform ethical guidelines. To read more about the Banker’s Oath, visit the website of the Dutch independent organization Foundation for Banking Ethics Enforcement (FBEE).

The above methods for encouraging voluntary compliance can be employed by compliance professionals simply and powerfully in routine compliance communications and awareness initiatives. Reminding employees of values – the purpose – helps to heighten the credibility and appeal of rules – the requirement – and provide a mission perspective to their engagement in the compliance program.

Round-up on the humanity of artificial intelligence

Human fascination in, and even obsession with, robots is nothing new. For many years people have imagined distant versions of the future where human interaction with different types of robots, androids, or other robotics products was a routine part of life both at work and at home. Sometimes these forward-looking scenarios focus on convenience, service, and speed. Much more often, however, when asked to contemplate a future with ubiquitous artificial intelligence (AI) technology imbedded alongside humans, thoughts stray into possible troubling or dark impacts on society. People worry about loss of humanity as technology predominates, or the possibility that robots could be misused or even gain sentience and have intentions to work against or harm humans.

In the past these scenarios, both of the positive advancement of society and of the potential for isolating, dangerous dystopia, were mostly relegated to science fiction books, Hollywood blockbuster movies, or what were seen as overactive imaginations or paranoid opinions of luddites. Now, however, the news is full every day of developments in AI technology that bring the once-imaginary potential of robots ever closer to present reality.

As technologists and business organizations consider the utility of advancement in AI, ethicists and corporate compliance programs must also consider the risk management issues that come along with robots and robotics. Technology which will have such a broad and deep impact on human life must be anticipated with thoughtful planning for the compliance risks which can arise. In particular the potential for sharing human traits with AI technology or imbedding AI technology in place of human judgment present provocative challenges.

  • Anticipating increased interactions with androids – robots that look like humans and can speak, walk, and otherwise “act” like humans would – leads to the logical question of will humans have relationships with androids and vice versa? This would be not just transactional interactions like giving and receiving directions, or speaking back and forth on a script written to take advantage of or increase machine learning within the android. Rather, this could be intimate, emotionally-significant exchanges that build real connections. How can this be when only one side of the equation – the human – is assumed to be able to feel and think freely? While technical production of robots that appear credibly human-like is still beyond the reach of current science, and giving them a compelling human presence that could fool or attract a human is even further away, work on these tasks is well underway and it is not unreasonable to consider possible consequences of these developments. Will humans feel empathy and other emotions for androids? Can people ever trust robots that seem to be, but aren’t, people? Will the lines between “us” and “them” blur? The burgeoning field of human-robot interaction research seeks to answer these questions and develop technology which responds to and considers these tensions.  Love in the Time of Robots 
  • On a similar note, when could machine learning become machine consciousness? Humans have embraced the usefulness of AI technologies which become smarter and more effective over time after they are exposed to more knowledge and experience. This is a great argument for deploying technology to support and improve efficiency and productivity. Everyone wants computers, networked devices, and other products that use advanced technology to work more accurately and easily. Machine consciousness, however, suggests independent sentience or judgment abilities, the potential of which unsettle humans. From a compliance and ethics perspective there is an extra curiosity inherent in this – what will be the morality of these machines if they achieve consciousness? Will they have a reliable code of ethics from which they do not stray and which comports with human societal expectations? Will they struggle with ethical decision-making and frameworks like humans do? Or will human and human-like practical ethics diverge completely?  Can Robots be Conscious? 
  • In 2016, David Hanson of Hanson Robotics created a humanoid robot named Sophia. At his prompting during a live demonstration at the SXSW festival, Sophia answered his question “Do you want to destroy humans?… Please say ‘no’” by saying, “OK. I will destroy humans.” Despite this somewhat alarming declaration, during the demonstration Sophia also said that she was essentially an input-output system, and therefore would treat humans the way humans treated her. The intended purpose of Sophia and future robots like her is to provide assistance in patient care at assisted living facilities and in visitor services at parks and events. In October 2017, Saudi Arabia recognized the potential of the AI technology which makes Sophia possible by granting her citizenship ahead of its Future Investment Initiative event. A robot that once said it would ‘destroy humans’ just became a robot citizen in Saudi Arabia
  • The development of humanoid robots will certainly become a bioethics issue in the future as the technology to take the human traits further becomes within reach. While there are so many compelling cases for how highly advanced AI could be good for the world, the risks of making them somehow too human will always be evocative and concerning to people. The gap between humans and human-like androids is called the uncanny valley, the space between organic and inorganic, natural and artificial, cognitive and learned. The suggestion that the future of human evolution could be “synthetic” – aided by or facilitated in the development androids and other robotics – presents a fascinating challenge to bioethics. Are humanoid robots objects or devices like computers or phones? It is necessary to consider the humans and androids in comparison to one other just as it is humans and animals, for example. This ethical dilemma gets to the root of what the literal meaning or definition of life is and what it takes for someone, or something, to be considered alive. Six Life-Like Robots That Prove The Future of Human Evolution is Synthetic
  • One of the potential uses of AI technology which worries people the most is in autonomous weapons. The technology in fact already exists for weapons which can be used against people without human intervention or supervision in deploying them. Militaries around the world have been quick to develop and adopt weapon technology that uses remote computing techniques to fly, drive, patrol, and track. However, this established use of this technology is either for non-weaponized purposes or, in the case of drones, deployment of weapons with a human controller. Fully automating this technology would in effect be giving AI-powered machines the decision-making ability that could lead to killing humans. Many technologists and academics are warning governments to consider preventing large-scale manufacturing of these weapons via pre-emptive treaty or other international law.  Ban on killer robots urgently needed, say scientists

As the diverse selection of stories above illustrates, the reach of robots, robotics, androids, and other developments within AI technology are certain to permeate and indeed redefine human life. This will not be in the distant or unperceived future. Rather, real impact from these advancements is even already starting to be seen, and there is only more to come. Governments, organizations, and individuals must make diligent risk assessment preparations to integrate this technology with human life in a harmonious and sustainable fashion.

Profiles of ethical leadership in sports coaching: Vince Lombardi

This is the fourth post in a month-long series of five that profile well-known sports coaches as examples of ethical leadership. The first post was about John Wooden and the Pyramid of Success he created while coaching basketball at UCLA. Johan Cruyff, legendary Dutch football player and manager, and the 14 Rules that are displayed at the fields that bear his name worldwide was the subject of the second post. Last Wednesday’s profile was of Jim Valvano, featuring an analysis on his views about leadership and success as featured in lines from his famous 1993 ESPY Awards speech. Today’s post focuses on Vince Lombardi, the NFL Hall of Fame coach, and his views on ethical leadership as expressed by his motivational speeches to his players and the public.

Vince Lombardi was a football player and coach who achieved great success over his 15 years working in the NFL before his death from cancer in 1970. Many critics consider Lombardi to have been one of the greatest coaches in the history of football, and this opinion was borne out in the records of the teams he coached and the accolades he received during his career. His tenure at the Green Bay Packers produced five NFL championships in the seven years from 1961-1967. He was elevated to the Pro Football Hall of Fame in 1971 and the NFL Super Bowl trophy was named in his honor. He has been admired and revered by many professional coaches, including the subject of last week’s ethical leadership profile, Jim Valvano. Therefore the effect of his powerful leadership style which will be explored below has been a legacy which has far outlived his own career.

Lombardi is known to have been a powerful, inspiring, and complex individual as a coach. He was known for his fiery, loud temper and authoritarian ways as much as he was for his insistence upon fairness and unconditional respect for the members of his football organizations. He demanded much from his players and in return was passionately devoted to them both as teams and as individuals. He would punish or call out players who did not meet his standards for effort or commitment, but also sought to actively recognize dedication and perseverance, which he upheld as critical values for success and achievement. He was devoutly religious yet open-eyed to prejudice and discrimination, which he strove to oppose with zero tolerance, and he was notable for his largely liberal beliefs.

Following the premature end of his life in 1970, Lombardi has been revered by football’s institutions, fans of the teams he coached, and people in the communities he impacted, especially in Wisconsin, New Jersey, and New York. Plays, movies, and books have been written about his influence as a coach and leader. Lombardi’s enduring legacy has been inspiring statements from speeches he made to players and other motivational comments attributed to him. Collections of these have been published and studied both by people working in sports and by others in all walks of life.

Of course, many of these statements are relevant not just to a football team preparing for a game or a coach seeking to motivate his players, but to life in general, and to a compliance professional interested with inspiring leadership ethics in specific. In this theme, here are five famous quotes by Lombardi, annotated with tips for how to apply these sentiments in defining compliance values for individuals and organizations:

  1. “Morally, the life of the organization must be of exemplary nature. This is one phase where the organization must not have criticism.”– Moral compromise cannot be a consequence of desire for success. Core values of an organization should be sacrosanct and not up for debate or critique which is focused toward diminishing or subjugating them to commercial or external pressures.
  2. “Success demands singleness of purpose.” – As discussed in last week’s profile of Valvano, individuals who drive toward goals with a defined and committed purpose, rather than a base desire for external recognition, are best prepared for true internal achievement that is sustainable and meaningful. Ethical decision-making requires this purpose-driven approach; commitment to values is certainly deserving of that singleness.
  3. “To be successful, a man must exert an effective influence upon his brothers and upon his associates, and the degree in which he accomplished this depends on the personality of the man.” – It is not just coaches who can inspire and elevate others with their examples. All individuals must have personal accountability for their moral codes and must strive to make ethical and compliant decisions. People must recognize the huge impact that their behavior has on those around them and commit to using this influence for the collective good. No person is an island in a culture of compliance. All levels must be engaged – tone at the top, mood in the middle, buzz at the bottom – and individuals must view their own reputations and relationships with others as important extensions of the values of the organization’s compliance program.
  4. “Watch your thoughts, they become your beliefs. Watch your beliefs, they become your words. Watch your words, they become your actions. Watch your actions, they become your habits. Watch your habits, they become your character.” – In a context where the organizational heuristics lean toward values-based and purpose-driven, individual ethics have a huge impact toward defining broad frameworks for making choices and defining strategy. Unethical decisions and misconduct often originate from environments where employees are isolated from the impact of their actions or where personal consequences are remote and not relatable.
  5. “A leader must identify himself within the group, must back up the group, even at the risk of displeasing superiors. He must believe that the group wants from him a sense of approval. If this feeling prevails, production, discipline, morale will be high, and in return, you can demand the cooperation to promote the goals of the community.” – Awareness and acceptance of personal accountability and consistent articulation of values and rules are critical for imbedding a culture of compliance. For that culture to succeed, leadership must speak up and out, and encourage others to safely and productively do the same. If individuals feel that their leaders espouse values, expect them to embrace those values, and provide a prevailing environment where both really matter, then the culture of compliance will be authentic and enduring.

For more powerful quotes from Lombardi on leadership and inner success, many of which are inspiring from an ethical perspective, check out the official website maintained in his name.

Also, don’t miss the final post in this series, next Wednesday, which will profile Gregg Popovich, who is the current coach of the San Antonio Spurs and is widely admired for his views on inclusion, political engagement, and personal accountability.