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.

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.

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.

Profiles of ethical leadership in sports coaching: Jim Valvano

This is the third in a month-long series of five posts that analyze the ethical leadership of famous sports coaches. The first post was about John Wooden, the beloved UCLA basketball coach and creator of the Pyramid of Success. Last Wednesday’s post focused on Johan Cruyff, the acclaimed Dutch footballer and manager of Ajax, Barcelona, and Catalonia football clubs, and his 14 Rules. Today’s profile will be about Jim Valvano’s perspective on leadership and success as expressed in the famous speech he gave at the ESPY Awards in 1993.

Jim Valvano was a NCAA basketball coach for 19 years, ten of those seasons at North Carolina State. He coached his teams at NC State to many winning seasons, including two tournament championships and two regular season championships, and for several years also served as athletic director there. He was also no stranger to controversy during this time, due to accusations of rules violations involving his players’ academic qualifications and financial activities, which led to substantial administrative pressure, scrutiny, and a variety of investigations. Though these numerous investigations revealed no outright major violations in recruiting or financial practices, Valvano ultimately resigned as athletic director in 1989 and in 1990, negotiated a settlement and resigned as basketball coach as well.

Following this somewhat ignoble end to his coaching career, Valvano worked as a broadcaster and became a motivational speaker. His speeches sometimes covered his version of the controversy at NC State or offered commentary to his audiences on how to handle and get over these unfortunate events and the character and reputational damage they present. This is not an unusual path for high-profile people to take after finding themselves in crises of confidence. Practical ethics are complex and transgressions in these professional dilemmas can lead a person to a moral reckoning and awakening of the true values that matter in life and how to embrace them authentically.

Valvano’s enduring legacy is a speech he made in this exact spirit at the first ESPY Awards in 1993. He was accepting the Arthur Ashe Courage and Humanitarian Award and at this time was in the throes of the glandular cancer which would take his life less than two months later. After announcing his intention to create an charitable foundation dedicated to finding the cure for cancer, he went on to speak emotionally and eloquently about individual success and his views on what made life worthwhile. This powerful perspective on purpose-driven living relied heavily on a definition of true success as inner and personal, not dictated by accolades from others or black-and-white “wins,” but rather a personal sense of accomplishment and completion that required no external justification.

This concept of internal success is important in an understanding of applied ethics and translates powerfully to a vision for individual accountability in a culture of compliance. In this theme, here are five significant statements from Valvano’s legendary speech, with suggestions for how to interpret these powerful insights for individual and organizational values to promote ethics and compliance:

  1. “To me there are three things we should all do every day. We should do this every day of our lives. Number one is laugh… Number two is think… And number three is, you should have your emotions moved to tears, could be happiness or joy… You do that seven days a week, you’re going to have something special.” – A balanced life is a sustainable one. This way, the pleasure of the highs will be memorable, the pain of the lows will fade, and the middle will be where the lessons from both come together for a lasting effect. As Johan Cruyff’s “Total Football” showed in last week’s profile, the only practical approach to life or business is a holistic one, with all factors and outcomes taken into fair contemplation. An even keel is a long-lasting perspective.
  2. “I always have to think about what’s important in life to me… Where you started; where you are; and where you’re going to be. Those are the three things that I try and do every day.” – This expresses a perspective on success that is grounded, measured, and reasonable. Success may be a line, or an arc, or a constellation of peaks and valleys, but the present must always maintain an attachment to the origin as well as to the ambition. This perspective can both humble and motivate individuals and organizations to consider, and be true to, their values.
  3. “It’s so important to know where you are. And I know where I am right now. How do you go from where you are to where you want to be? … I think you have to have an enthusiasm for life. You have to have a dream, a goal. And you have to be willing to work for it.” – Success is equal parts planning and effort. In life as well as in business, if you don’t work for it, it’s not worth having and might not be possible to keep. Professionals should be passionate about and engaged the work that they do and the reasons for which they do it – not a paycheck or external recognition, but as Valvano says, enthusiasm, vision, and commitment. Ethical decision-making is only possible if individuals are purpose-driven and accordingly, so long as they hold themselves accountable to that purpose.
  4. “I urge all of you… to be enthusiastic every day… to keep your dreams alive in spite of problems whatever you have. The ability to be able to work hard for your dreams to come true, to become a reality.” – Adversity is always a great challenge to character ethic. Be it accusations of wrongdoing, confrontation with personal moral failures, opposition and criticism, doubt and uncertainty, or even physical illness and disease, resilience and perseverance are the only remedy. Continuing commitment to core values, even when feeding forward input or external changes and making adjustments is necessary, as is appreciation of the work and effort required to reach goals. With this in mind, genuine inner success is achievable.
  5. “Cancer can take away all my physical ability. It cannot touch my mind; it cannot touch my heart; and it cannot touch my soul. And those three things are going to carry on forever.” – The closing and perhaps most famous and poignant lines of Valvano’s speech, the lesson from Valvano’s conviction to endure despite his illness and physical diminishment is universal to all human endeavors. Dignity, legacy, and respect are not circumstantial and cannot be taken from a person unless freely compromised. This goes to the heart of personal ethics and morality – a person’s own register of right and wrong, internal governor and code should be untouchable and can be relied upon in even the darkest and most uncertain times.

For Valvano’s powerful 1993 ESPY speech, watch it here:

Don’t forget to check back for next Wednesday’s post, which will be about Vince Lombardi, the NFL Hall of Fame coach (and the role model of Jim Valvano, as it happens), and clues about how he saw ethical leadership based on famous statements from his statements to players and motivational speeches. The final post in this series, on November 29, will profile Gregg Popovich, the current coach of the San Antonio Spurs with a progressive view toward people management of his players and political engagement as an expression of leadership.

Tips for improving employee accountability in compliance programs

The most ambitious culture of compliance paired with the most robust controls framework still cannot succeed without employee adherence. Employees who don’t know the correct thing to do, or those who make an unethical or non-compliant decision despite knowing, can be addressed with awareness communication in the first case or remedial action in the second case.

However, the more frequent and challenging scenario is that employees have received information about compliance risk management priorities and ethical culture at their organization. They understand this information well enough and maybe even admire the aims of the compliance program, but there’s a problem – they don’t see themselves as having an active role in it.

The best efforts of compliance programs will always be overcome by apathetic or unengaged employees who don’t see themselves as having personal compliance responsibilities. In cybersecurity, for example, the best IT systems with the most up-to-date risk controls structure will still be defeated by an employee who falls for a phishing scheme or leaves behind an unsecured laptop in a public place. Some mistakes are unavoidable, of course, just like some risks can only be mitigated or accepted. However, many other errors, acts of misconduct, or risk factors can be prevented with the appropriate individual vigilance and diligence.

So how can a corporate compliance program emphasize to employees that individual responsibility is the fundamental defense in any risk and control framework? Too many solutions from management or consultancy rely heavily on data solutions and systems approaches to addressing compliance risk. The logic goes: failures of existing compliance programs to prevent ever-evolving fraud and misconduct are unfortunately not unusual, so why not simply blame human misjudgment or incompetence for inadequate controls and therefore just automate processes whenever possible?

The above is a cynical and defeatist attitude toward corporate compliance; if management or its advisors decides that corporate compliance will fail, then it certainly will do so. However, removing the obstacles to individual responsibility is an important step to empowering organizational integrity. Outsourcing or digitalizing analysis and advisory work is an artificial, external solution. It may expedite or simplify some aspects of working with compliance risk management, but it cannot ever be as effective as a values-based approach that creates a corporate culture where good judgment and ethical decision-making are incentivized and supported.

Indeed the first, and probably best, solution for raising the standard of compliance programs and their controls is to promote employee engagement in these across all levels of the organization. This starts with individual accountability, which compliance professionals and senior management can nudge employees toward embracing these ways:

  • Walk the walk: Senior management should weave a thread of the corporate cultural values throughout all matters that touch an employee’s working life. This needs to be consistent and visible. Communication should be simple and straightforward, practical and not preachy, but it should express and reinforce the cultural values. In HR matters, for example, transparency should be communicated and modeled. Employees must see the corporate cultural values explicitly expressed as they experience corporate administration across the organization. This brings the values from mere words to a living system in which they are participants.
  • Nudge with timely reminders: Regulatory, legal, and policy requirements change rapidly. Employees that are trained regularly should be respected for what they already know; heavy-handed instruction can be seen as condescending. However, reminders upon key messaging events (anniversaries, completion of investigations, or announcements of strategies) or updates when there are new guidelines or expectations are critical. These reminders can act as nudges toward appropriate behavior for individuals whose attention may have moved on or whose understanding was out of date.
  • Work against culture of fear: People often think about speaking up in the workplace in terms of following an internal escalation process or being a whistleblower. To some people, speaking up by challenging an established procedure or an experienced colleague may seem unprofessional or presumptuous. The possibility of being opposed or facing retribution can be very scary for employees who might want to express uncertainty or ask questions. Corporate compliance programs have a responsibility to create a culture where speaking up routinely is safe and supported. A relationship-based approach to business compliance advisory is a great first step toward combating the fear factor and helping employees to speak up to check understanding or challenge practices. Involved employees are more likely to be accountable ones.
  • Actively address accountability gaps: When it is evident that an employee or group of employees do not embrace accountability in compliance risk management, address it, but not punitively. Open discussion can be mutually beneficial. Take the opportunity to express that individual responsibility is expected, and also to listen to the limitations or uncertainties that may provide an explanation for why it’s missing.
  • Insist on consequences: Disciplinary action is never the intended outcome for any employee-management relationship. Ideally everyone would want to and be able to do the right things all the time, but clearly mistakes and misconduct happen. Good people/bad people dichotomies are classic but not necessarily helpful. In reality, it’s most important to establish from the beginning that consequences for doing the wrong thing exist and will be enforced fairly and meaningfully.

There will always be people in organizations who either are in need of training or resourcing attention (wanting to do the right thing but not being properly equipped) or people who are not cultural fits (wanting to do the wrong thing despite organizational priorities). Engaging these people where possible is critical, just as holding all others accountable for their actions and responsibilities is the frontline defense most important to compliance risk management.

Profiles of ethical leadership in sports coaching: Johan Cruyff

This is the second in a month-long series of five posts that discuss successful sports coaches in terms of their ethical leadership qualities. Last Wednesday’s post was about John Wooden, the visionary UCLA basketball coach. Today’s post will focus on Johan Cruyff, the acclaimed Dutch footballer and manager of Ajax, Barcelona, and Catalonia football clubs. Next week, the profile will be about Jim Valvano’s leadership ethic as expressed in the famous speech he gave at the ESPY Awards in 1993, two mere months before he died of cancer. On November 22, the post will be about Vince Lombardi, the NFL Hall of Fame coach, and clues about how he saw ethical leadership based on some of his most famous public statements. The fifth post in this series, on November 29, will study Gregg Popovich, a current NBA coach with a progressive view toward developing his team as both players and people.

Johan Cruyff is widely thought of as one of the greatest football players of all time, having won the Ballon d’Or three times and playing many extremely successful seasons for Ajax (1964-1973) and Barcelona (1973-1978) in club play and the Netherlands (1966-1977) in international play. Cruyff is equally regarded for his impressive achievements as a club manager. His innovations while at the helm of Ajax and Barcelona football clubs laid the generational foundations of coaching philosophy that continue to shape the directions of those teams and their youth academies, as well as those of many others.

To learn more about Cruyff’s life and accomplishments as a player, read this profile from The Guardian published after his death in March 2016.

Cruyff, regarded by many as a technically perfect football player, was able to devote his energy to creative organizational strategies to make the game more cooperative and dynamic. From his perspective, technique went far beyond fundamentals of football that could be learned from rote practice of drills. Rather, real playing ability came from having a fluency and versatility with the game that allowed players to connect to one another and work in an instinctive and flexible system together on the pitch.

Cruyff also receives special mention for his approach to the game that emphasized morality via simplicity of play. While regarding football as a beautiful game, this was not merely based on entertainment value or competitive stakes that might be exciting, but also on efficiency and mental strategy, where the mind’s plan facilitates the body’s actions. This is a powerful consciousness that elevates a deeper existential, internal success over the fleeting external recognition of a win-lose result that was not achieved by a personal commitment to greatness via integrity and discipline.

Cruyff’s strong values toward the game and life are most poignantly embodied in his “14 rules,” which are displayed in each of 200 Cruyff Courts set up in countries all over the world for children to use freely to play football together.   These 14 basic rules are fundamental for all players in football match to follow, but they also provide a guiding philosophy for a values-based approach to life. Applying these as both personal and business management principles allows an individual to seek inner satisfaction and success via connections to and cooperation with others, personal accountability, authenticity, and informed ambition.

Cruyff’s 14 rules, annotated with suggestions for their application to corporate cultural principles in interests of promoting organizational and employee integrity, are as follows:

  1. Team player – To accomplish things, you have to do them together. – True success is achieved by focusing on collaboration and cooperation, not making isolated decisions in disconnected processes.
  2. Responsibility Take care of things as if they were your own. – Individual ownership of risks and recognition of each person’s role in their management is fundamental to any defense strategy as well as necessary for a genuine culture of compliance at all organizational levels.
  3. Respect – Respect one another. – Businesses must have zero tolerance for non-inclusive or abusive behavior; incidences of it must be addressed seriously and mitigated or prevented from reoccurring when possible.
  4. Integration – Involve others when possible. – Work together to share responsibility – invoking praise when duly earned, and liability when risks are not managed.
  5. Initiative Dare to try something new. – Foster and contribute to a culture of speaking up and out. Challenge heuristics and routines which can drive unethical decision making and narrow cognitive frameworks.
  6. Coaching Always help each other within a team. – Regard the organization as an interdependent unit to support an integrated style of decision-making and working.
  7. Personality Be yourself. – People should maintain their personal code of ethics and sense of right and wrong that they have in life, at work. Good people should not be afraid or unable to do good things.
  8. Social involvement – Interaction is crucial, both in sport and in life. – Be active champions for ethical processes and work together to promote them. Isolation is toxic to collective integrity.
  9. Technique – Know the basics. – Have or get the information needed to remain in constructive compliance with rules, regulations, and laws. Stay up to date or in front of them.
  10. Tactics – Know what to do. – Have a strategy that is flexible but driven by defined values and a thoughtful understanding of risks. Prepare work based on a plan and in agreed terms.
  11. Development – Sport strengthens body and soul. – Stay up to date or in front of the guidelines that form the controls framework. Feed-forward ideas, letting future productivity benefit from past performance.
  12. Learning – Try to learn something new every day. – Be open to and informed about different perspectives and opportunities. Seek knowledge and evaluate strategy based on it, not based on what is easy or fast.
  13. Play together – An essential part of any game. – Share values and manage risks by working together. Don’t be solicited for advice or seek an opinion; have an evolving and ongoing relationship.
  14. Creativity – Bring beauty to the sport. – Be passionate and on the lookout for novel approaches that will provide elegant solutions to dilemmas.

Cruyff’s 14 rules are about so much more than football or sport. These rules are succinct, relatable suggestions for how to live a moral life in harmony with others and in pursuit of self-sustaining accomplishments. This emphasis on values drives intellectual curiosity, physical effort, mental development, and individual accountability. These powerful principles promote integrity in all areas of life and work.

To learn more about Johan Cruyff and his undeniable legacy in football and leadership, check out this Football’s Greatest feature on him:

Also, make sure to read next Wednesday’s post, when this series continues on to look at Jim Valvano, a famed NCAA basketball coach and, later, broadcaster and motivational speaker, and his legendary speech at the first ESPY Awards in 1993 which makes a powerful, simple statement on integrity and internal success.

GRC for compliance professionals

Compliance as a function is sometimes subject to varying definitions. Across different companies, industries, and cultures, organizational perspectives on the purpose and scope of a compliance program can vary. Some see compliance as an alternative to or close relation of the legal department, while others position it much more independently, perhaps as an intermediary between the business lines and audit. Still others may see compliance as the depository for risk-based support activities that do not otherwise fall cleanly into any other established unit.

As previously discussed on this blog, and as this blog will continue to ensure to express, the autonomy and visibility of compliance is integral to the integrity and sustainability of an organization’s employees and business strategy. Compliance blends a rules-based approach with a values-based approach to reconcile ethical expectations with legal obligations and technical requirements.

Professionals who work with interpreting legal and regulatory guidance and implementing these into business practices will likely recognize the acronym “GRC.” GRC stands for governance, risk management, and compliance. This umbrella term integrates these functions to describe the operational activities undertaken by an organization to execute plans, manage risk, and encourage integrity.

The GRC model refers to process themes, not necessarily functional units of an organization. Indeed, the three themes of GRC may be included in operational tasks and across numerous independent departments, including HR, finance, IT, audit, and at the board level, in addition to the obvious areas such as risk, legal, and compliance.

GRC can be seen as a discipline that seeks to coordinate the flow of information and ownership of risk so that the activities and processes it encompasses are effectively and efficiently incorporated. As organizations become bigger, this discipline becomes all the more important for keeping channels of communication open and clear, both up and down silos as well as across business areas.

Ethical decision-making thrives in an integrated system where objectives are clearly expressed and information-sharing is transparent and relied-upon.   Elevating a coordinated GRC discipline can foster a communication regimen in an organization where reasonableness and feedback rather than heuristics and routine dominate. Equity and integrity can thrive if actions are taken openly and cooperatively rather than in isolation.

In the ever-changing regulatory landscape of modern business, it is so important that an organization’s GRC activities be coordinated so that work is not duplicated or wasted and gaps are filled rather than passed over with tunnel vision. These functions share stakeholders and objectives, and therefore should share information to maximize meaningful impact and minimize redundant effort.

The basic concepts of the GRC approach are all useful for a compliance officer or other professional to consider:

  • Governance: This refers to the management control framework used by an organization’s senior leadership, relying on management information from across the organization in order to direct and control the overall strategy and operation of an organization. This concerns major existential questions for the organization, such as – what are the roles of leaders at all levels? What are the reporting mechanisms and what checks and balances exist for these? How does business strategy translate into directions to various business units and how are these instructions communicated to employees? Having an informed perspective on the organization’s governance objectives is very important for a compliance officer because this gives insight to the tone at the top and the mechanism through which these critical values become concrete practices.
  • Risk management: Risk management is the identification, assessment, and response to risk factors which may have an impact on an organization’s activities. This also includes considering risks which do not have an impact and ascertaining that this evaluation remains correct and current as fluid business objectives and conditions may change. All organizations are subject to some risks, such as operational risk, technological risk, and financial risk, while others may be determined by the industry in which they operate, such as market risk, liquidity risk, political risk, third-party risk, and product-specific risks. Risk management entails planning and implementing controls in order to address these risks, either by mitigating them, changing strategy or practice to eliminate them, accepting them, or transferring them to a service provider or partner who is positioned to best respond to them. Legal, legislative, and regulatory risks are of particular interest to compliance officers, as are compliance-centric risks such as reputational risk. Compliance officers should take risk identification and assessment well into account when planning compliance program objectives so that these can be fine-tuned to the emergent and most important needs the business faces in this area.
  • Compliance: Of course, staying in good standing with supervisory authorities and ensuring that business practices and procedures meet standards and requirements set by external laws and regulations as well as internal policies and procedures, ensures that the work done in governance and risk management activities is properly directed and sufficiently supported. An on-going assessment and prioritization of the compliance program’s effectiveness and appropriateness is necessary to ensure that the controls in place are up-to-date and working as intended.

The themes above are all germane to the objectives of a compliance program and can be referred to in seeking buy-in from senior management or supervisory board members, with whom ultimate responsibility for establishing and executing these systemic processes rests.

Profiles of ethical leadership in sports coaching: John Wooden

This is the first in a month-long series of five posts about historically significant sports coaches as exemplary models for ethical leadership values. Today’s post will focus on John Wooden, the legendary UCLA basketball coach. November 8th’s post will analyze the famous “14 rules” of Johan Cruyff as business values to promote organizational and employee integrity. On November 15, the profile will be about Jim Valvano and the inspiring speech he gave at the ESPY Awards only two months before his untimely death in 1993. Vince Lombardi, the NFL Hall of Fame coach, and his insights on the ethics of leadership and performance will be the focus on November 22. Finally, on November 29, a contemporary coach will be the final profile along with the previous leaders from sports history, with the focus on NBA coach Gregg Popovich.

These coaches are all beloved, legendary figures whose importance in society extends far beyond their teams, and for good reason.   Beyond inspiring players and other coaches who develop with them or work alongside them, the ideas coaches share about motivation, personal growth, attitude, and performance can easily translate from the court, pitch, or field to all areas of life.

No discussion of legendary coaches in sports history is complete without mentioning John Wooden, so it is logical to start this inquiry with him. John Wooden was the head basketball coach at the University of California Los Angeles from 1948 until 1975. During that time, he coached the team to ten NCAA national championships in 12 years, seven of those in a row. For his many storied accomplishments at UCLA, Wooden was named coach of the year six times.

Apart from his winning record, Wooden is renowned for his popularity among his former players, many of whom recognized him as having shaped their lives positively. He is well-known for his organizational leadership and insights which have been translated as tips for success in life in general, often relying on simple and straightforward inspirations for positive behavior and attitude. Wooden defined many leadership and performance principles to inspire his players to achieve their best in basketball and life. These were embodied by, for example, his Seven Point Creed, which included being true to yourself, helping others, building relationships, seeking advice, and being thankful, and the Pyramid of Success.

The Pyramid of Success describes 15 blocks which, when considered in performance and strategy, support competitive achievements which can be reached through a values-based approach. These 15 qualities are: (1) industriousness, friendship, loyalty, cooperation, and enthusiasm; (2) self-control, alertness, intitiative, and intentness; (3) condition, skill, and team spirit; (4) poise and confidence; and, culminating in, (5) competitive greatness. These are supported by, on one hand, from bottom to top: ambition, adaptability, resourcefulness, fight, and faith; and on the other hand also from bottom to top: by sincerity, honesty, reliability, integrity, and patience.

This balanced approach demands that any individual hoping to reach competitive greatness must take into consideration the personal qualities and resilience that are required to get there. In this model, quick wins or external satisfaction are not emphasized; instead, building character ethic and cultivating a measured path to the desired achievement.   These values are not special to basketball or sport. They are also not mere business principles. They are a life philosophy and paradigm which an individual can consistently carry though all of his or hers endeavors. The hard work a person devotes to the dual goals of sustaining faith and patience provide the momentum for the culmination in success.

For an interactive look at this, check out the website memoralizing him, which has a section devoted to the Pyramid of Success.

The key takeaway from the Pyramid of Success, and many of Wooden’s finer management and development insights, is that success and winning are not synonyms. A person can reach competitive greatness, the ultimate stage of the Pyramid of Success, but that does not mean the result will be winning every time thereafter. By the same token, an individual game or effort can result in a win, but that does not mean intrinsic success has been achieved in a sustainable, credible way.

In Wooden’s words in his 2001 TED talk (linked below), success is defined as “peace of mind attained only through self-satisfaction in knowing you made the effort to do the best of which you’re capable.” This is not something others can judge or define and does not come from an external performance or perception. This sense of self-accomplishment, win or lose, prevail or fail, can only be reached through hard work, the commitment to which is supported by equal doses of patience and faith.

Watch and read Wooden’s TED talk, “The difference between winning and succeeding,” here.

Having a commitment to this internally-motivated model of success is powerful for determining that the results of one’s effort will be about the integrity with which it was made. Individuals and organizations can inspire a values-based approach to work from this management mechanism. Getting there is the most important part of the process of “being” there. If the emphasis is on winning, competition, profit, attention, and external accolades, then the internal values will be missing to sustain the accomplishment. But, if the emphasis is on growth, hard work, relationships, learning, preparing, and internal satisfaction, then the greatness achieved will last long enough to get the win and keep much more after that.

For a great study of the enduring legacy of John Wooden, check out this Sports Illustrated article by Seth Davis from March 2017.

Also, don’t forget to check back next Wednesday when this series continues on to look at Johan Cruyff, legendary Dutch footballer and manager whose coaching philosophy is credited with revolutionizing the game of football.

Selected TED & TEDx talks on ethical dilemmas

An ethical dilemma is a problem in decision-making between two or more possible choices which involve conflicting interests and challenging possible consequences. Often this can be understood as a scenario in which making one decision has an impact on the interests involved in the other decision(s) not made. Choosing to not make a decision is also, in its own right, a choice which implies these consequential dynamics. The below TED/TEDx talks are a sampling of some different dilemmas encountered and the ways that the speakers have thought about and attempted to resolve them.

  • The ethical dilemma of designer babies (Paul Knoepfler) – Biotechnology which was once the stuff of science fiction is now becoming an everyday reality, or at least a possibility that is easy to imagine for the not-so-distant future. For many years now there have been ethical questions about the use of gene editing technology in human embryos. This could allow scientists to mitigate the risk of certain auto-immune or congenital diseases, which would be a marvel of modern medicine. However, it could also make the way for individuals to use the technology to also alter physical appearance and pre-determine many of a person’s traits, perhaps also eventually personality characteristics. What answers does bioethics have for this dilemma? Is it worth the risks, too dangerous to justify the benefits, or somewhere in between – a technology that should be progressively and thoughtfully developed with both those risks and those benefits in careful balance?

 

  • Can we engineer the end of ageing? (Daisy Robinton) – While the prior talk considers the beginning of life, there are also bioethical considerations to scientific advancements made concerning the end of life also. Just as there can be cellular interventions on the biological makeup of embryos, therapeutic mechanisms of stem cell identity may already be useful in increasing longevity and health, such as by reversing the growth of cancerous cells or addressing other developmental diseases. However, what about the possibly to “edit” one’s DNA not for survival or to cure a sickness, but to improve capabilities or change aesthetic qualities? If some physiological differences are editable at the cellular then is it ethical to do so?

 

  • The Social Dilemma of Driverless Cars (Iyad Rahwan) – Self-driving cars have been in the news a lot recently as leading organizations such as Ford, General Motors, Tesla, and even Samsung are making major investments in developing field. In the US, the federal government has indicated that it prefers to let technological innovation take precedence over anticipatory regulation, perhaps taking lessons learned from the initial failure of the electric car industry in the 1990s and early 2000s. The artificial intelligence of self-driving cars is ethically challenging, in consideration that these driverless vehicles will share the road with pedestrians and conventional vehicles. Will they be safer than cars with human drivers, or do they bring up all kinds of new safety and privacy concerns?

 

  • Machiavelli’s Dilemma (Matt Kohut) – More to the point of typical everyday interactions than the abstractions of the limits of medicine and technology, what about character judgments? The classic question remains – do we want to be loved or feared? Liked or respected? Most people of course would say some combination of both, but in first impressions or in difficult leadership situations, sometimes the choice to be one at the expense of the other is unavoidable.

 

  • The paradox of choice (Barry Schwartz) – The thing of all these different dilemmas have in common is, of course, choices that individuals, organizations, and sometimes society as a whole must make. Facing the responsibility of making a choice indicates that there is freedom of choice in the first place. The privilege of decision-making can also be a burden. One must be able to decide in the beginning in order to feel some sense of personal dissatisfaction or insufficiency provoked by the idea that other choices, and other outcomes could have been possible.

 

As the above demonstrates, there are many diverse examples of ethical dilemmas which come from all areas of business and life. This effectively points out how ubiquitous these challenging situations are. From simple, everyday interactions to matters of life and death, ethical dilemmas present challenging, compelling moral questions.

Communication strategies for increasing employee engagement in compliance programs

Every compliance professional’s strategic annual plan will include seeking increased employee engagement in and attention to the organization’s compliance program. Communication strategies must be carefully devised with the goal in mind of making compliance vivid and interesting to employees. The compliance message can quickly become routine and dry: sign an attestation, request pre-approval, complete a checklist. This sort of messaging alienates employees rather than engaging them. They have only a small function in the compliance operations this way. Nothing is learned or shared, they are just doing a “tick the box” type exercise.

Instead, the true aspiration of the compliance messaging is that employees take interest, learn something new, ask questions, and feel connected to the story of the organization’s compliance program. This is accomplished via effective and appealing communication that speaks to all audiences and sets a new, compelling tone.

  • Key moment messaging: Compliance is highly relatable to current events and new stories. Therefore compliance communications should take full advantage of key moment messaging opportunities. Relate communication topics to outside events to make the objectives of the compliance program even more concrete. For example, if there is a major earthquake somewhere in the world and your office is located in Southern California, take that opportunity to engage with employees about disaster recovery and business continuity policies and procedures. Their interest will already be heightened and the necessity of the information will be at its most tangible.
  • Positive reinforcement: Start with a kudos, congratulations, or positive sentiment. Any action that needs to be taken or improvement that needs to be made based upon the communication will be much better received if the message gets off to a welcoming start. Set a productive tone by thanking employees for their participation in the last request or calling out good insights or high engagement. Then build off that encouragement to bring in the next steps needed and issue the call to action.
  • Branding: Branding and marketing are now important considerations across all business lines and functions. Compliance is not immune to this, as messages from so many sources fight among themselves for precious attention and airtime from employees. Therefore compliance professionals must carefully consider branding options that will maintain the substantive content of their communications yet be adequately branded to be appealing. Using humor or a catchy, fun theme to introduce the communication, before getting to the meat of the message, can provoke curiosity and prompt engagement. Don’t take it too far and make it a joke – but a little bit of amusement can go a long way.
  • Give visuals/shortcuts: On a similar note, think about making simple takeaways from the communication, however complex its overall message. One way to do this is to provide a visual, like an example of a new form that has to be filled as standard procedure, or a chart showing results on an initiative over previous periods and projected future results. If a visual is not applicable, try using acronyms or slogans that will work as mnemonics to help people remember your message and keep the meaning in mind.
  • Make it interactive: The best way to engage employees in compliance communications is to concretely incorporate them in it. Make the messages interactive for them. Ask an open-ended question and promote any responses received so that employees know the request for input is credible. Take a poll or offer a quiz. This way, employees can share in the mission and the effort by weighing in themselves, which allows them to personalize the message and be more likely to remember it.

To interest and appeal to all employees, compliance communications should not be generic or routine. Taking advantage of opportunities to make compliance relatable, and capitalizing on human interest or emotional connections that can be made, will help to make the mission of the compliance program much more interesting and effective.