Practical insights for compliance and ethics professionals and commentary on the intersection of compliance and culture.

Integrity of game play: Unethical leadership by coaches

This is the fifth in a series of five posts on the topic of integrity of game play. The first post in the series was about the negative impact of player misconduct on sportsmanship and game outcomes. The second post pondered whether tanking can ever be ethical and judged numerous examples of the practice in different sports to assess potential morality of these actions. The third post covered referee bias in different sports, analyzing its prevalence or presumptions of it and how this type of bias may relate to overall ethical decision-making and choice theory.  Last week’s post discussed examples of organizational cheating operations by teams.  Today’s post, the fifth and final in the series, will delve into examples of unethical leadership by coaches.

Coaches are some of the most popular, visible, and influential leaders in society. Their tone and conduct can have a ripple effect on the behavior by and achievements of the players and teams they influence. To the public, coaches often provide the institutional identity for the team, expressing their mission and values in the media as well as defining the terms on which the organization wishes to compete and be known. Within team organizations, coaches are the most important people managers, tasked with both developing individuals and demonstrating operational commitment to the team’s strategy for the game, season, and beyond.

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Insights from self-development and coaching for compliance officers

This is the second in a series of four posts on insights for compliance officers from different fields of study.  Last week’s post was about lessons from psychology regarding motivation and choice, from prominent figures such as Abraham Maslow and Sheena Iyengar.  Today’s post will discuss insights from self-development and coaching.  Next Tuesday’s post will be about insights from behavioral economics.  Finally, on March 13, the last post in this series will discuss how business management theories can be useful for compliance officers.

Much like the insights from psychology discussed in last week’s post linked above, theory of self-development and coaching can be very useful for creating and cultivating a culture of compliance at both the individual and organizational levels.  Focusing on thoughtful growth and progress, inner success and ethical achievement, and a values-based, sustainable approach to strategy and mission are all necessary for fostering integrity in organizations and groups or people within them.  Motivational writings on paths to self-development and tips for effective coaching can translate easily to informing a compliance culture.

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Ethical leadership in the Eagles’ Super Bowl LII victory

When the Eagles beat the Patriots in Super Bowl LII on February 4, 2018, they did much more than win a football championship.  To Eagles fans, the victory represented the culmination of 52 years spent waiting for their team to bring the Vince Lombardi Trophy home to Philadelphia.  Feeling disliked, disrespected, and underestimated by rivals and analysts alike, the Eagles and their fans leaned into their adopted underdog persona, making the ultimate win all the more powerful.

The media attention around the aftermath of the game has focused on the jubilation and vindication, amidst this prior doubt and dismissal, felt by the fans, the players, the coaching staff, and everyone affiliated with the team.  All this was capped off by a joyful parade down Broad Street to commemorate the accomplishment.

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Compliance and Stephen R. Covey’s “emotional bank accounts”

Stephen R. Covey’s famed self-development insights can also be applied to compliance and ethics. The acclaimed author of the worldwide best seller The 7 Habits of Highly Effective People has provided motivation to managers, students, and progressive people for many years. Covey’s work was far more than just a self-help guide or a management how-to. With his emphasis on character ethic as well as values and principles, Covey created an interesting body of work that can be broadly used in crafting the business mission statements he endorses so heartily, from a compliance and ethics and perspective.

This post takes an in-depth look at each one of Covey’s 7 Habits to explore the applicability of each one for the work and goals of compliance professionals. All seven of the habits encourage conduct that is positive and productive for compliance risk awareness. Inner success, sustainable and functional interdependence, and strategic, purpose-driven vision are just some examples of the compliance culture qualities that the 7 Habits consistently endorse. Trustworthiness, credibility, and honesty are the cornerstones of individual relationships and organizational identities in Covey’s system.

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Happy Martin Luther King Jr. Day!

Happy Martin Luther King Jr. Day from Compliance Culture!

In honor of the holiday, please check out the below selections from some sermons and speeches delivered by Dr. King which are especially pertinent to ethics and morality.  These profound and incisive words can inspire not just spiritual and philosophical observations, but are also useful to consider in formulating individual and organizational values and cultural identity.

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Selected TED/TEDx talks on integrity

Integrity as both a personal and an organizational value is one of the central and recurring themes of this blog. Promoting and supporting integrity in individuals as well as in the groups in which they live and work is essential to encouraging cultures of compliance and ethical decision-making. Indeed, the foundation of the moral conduct people wish to see in each other and in their institutions in order to enhance the stature of truth and honesty in today’s complicated, interconnected world starts with placing personal emphasis on integrity and character ethic. With a strong and well-articulated individual commitment to moral engagement, people can purposefully contribute to the integrity of the communities in which they live, the groups in which they gather, and the organizations in which they work.

  • Aligning integrity with identity (Lester Tanaka) – Commitment to any character ethic value must be authentic. A person cannot decide to have integrity without actually embracing the honesty, judgment, fairness, transparency, and credibility that goes along with possessing this trait. Claiming to have it, without actually genuinely imbedding it, goes against the grain of the entire concept of integrity itself. Therefore individuals must, as Lester Tanaka suggests, make concrete and meaningful for themselves the interrelationship between the mental and the moral. A person’s identity should be aligned with and connected to the value of integrity and their intention to live with it. Therefore, all the other traits for which an individual has an affinity should be consistent with the goal of integrity. Self-examination and self-reflection will be both necessary to identify these corresponding characteristics as well as important for thoughtful and organic personal integrity.

 

 

  • Integrity as a currency for leadership (Barth Nnaji) – Integrity is also a core value for leadership. When faced with opposition or adversity, challenge or doubt, ethical leaders can always rely upon their integrity to represent themselves as credible, rise above the fray, and maintain a firm grip on ethical standards for decision-making and conduct. One of the differences between a manager and an ethical leader is, in fact, this commitment to their sense of integrity and the feeling of a strong responsibility to resist negative temptation or becoming overwhelmed by the magnitude of their tasks. True leaders stick to their own values and indeed promote their own integrity as the “currency” needed to get things done in collaboration with other people and organizations. Leaders who consider their reputations as one of their main assets would seek to protect the way they are seen by others by staying true to the expectations for their credibility and reliability. This way, people who lead with integrity become people with whom others wish to be associated, compared, and involved.

 

 

  • Building integrity – keeping promises (Erick Rainey) – Establishing integrity does not have to be an academic or theoretical challenge with abstract and lofty metrics by which its success is measured. Having integrity is as simple as keeping promises. Walking the walk, taking responsibility, and following through are simple but incredibly impactful actions which, when repeated, establish a pattern of integrity and worthiness of trust and reliance. This goes for individuals as well as for organizations. Delivering on commitments or being honest and transparent about it when it’s not possible to do so puts the value of integrity into powerful action.

 

 

  • Integrity and authenticity don’t make you trustworthy (Struan Robertson) – As noted in this earlier post, expectations for and ideas about trust, honesty, and the truth are all being transformed by today’s digital society. Shifting moral evaluations and perceptions of what is or is not true too often promote a convincing and compelling brand of dishonesty over difficult or complicated truth. In this environment there are many complex factors against true credibility and integrity. Simply appearing to be “good” or wanting to identify others as “evil” is not sufficient. Being relied upon is also not the same as being trusted or trustworthy.   As discussed above, commitment to integrity has to be both authentic and practical. An individual and all the individuals which make up organizations have to have an organic, real commitment to integrity in order to truly act with it, rather than to just pretend or attempt at it.

 

  • Integrity and the Life of the Planet (Zale Zeviar) – Apart from the integrity of individuals in both private life and the work place, corporate integrity is so important in society’s attempts to solve huge challenges, such as making environmentally-friendly consumer choices. The transparency and openness that acting with integrity and moral certitude can bring is also applicable to business core values. Accountability for earth-friendly business practices and products is just one expression of corporate social responsibility that exhibits business integrity. Small changes by consumers can be enabled by community and business values which can help the whole system to aspire to a higher level of integrity. This “corporate consciousness” is an active expression of integrity that spreads, aligning all the players in the chain universally around integrity as the common theme.

As shown above, defining integrity as a core value in all areas of life – self-identification, leadership, relationships with others, community engagement, social responsibility – is a powerful, purpose-driven approach. A commitment to recognizing integrity as a virtue and using a strong internal sense of its importance for one’s personal moral code enables individuals to be credible and responsible and to model these values to each other. With time, institutions and organizations will reflect the integrity promoted by the individuals within them, elevating the ethical register of society.

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Inexperienced CEOs and immature compliance cultures

It is never too early, or too burdensome, to create a fundamental business compliance program.  Small businesses, new businesses, and experimental businesses can all benefit tremendously from the foundation and organizational structure that a basic risk control framework can bring.  A disruptive or innovative company does not have to eschew everything about traditional business in favor of transformative and novel ways of working.  It is fair that some strategies or philosophies may be seen as staid or unlikely to keep pace with the competitive and development pressures these businesses face.  However, the common sense responsibility (values-based) and implementation of legal and regulatory guidelines (rules-based) impact of a corporate compliance culture encourages and supports business sustainability.

All too often, however, start-up companies lack this structural backbone.  They do not have adequate policies and procedures in place, are unable to cope with the employee and supervisory demands that emerge in their workplaces and marketplaces, and grow into business practices without the controls framework and governance, risk management, and compliance structures that they find they need.  Most concerningly of all, with their attention span devoted to survival and then growth, these companies find themselves without genuine and integrity-supporting corporate cultures, and attempts to impose them over the top of the existing environment are artificial and difficult.

This challenge becomes only stronger when the company without a confident hold on compliance and ethics building blocks is dominated by a founder or CEO who is,  him or herself, on unproven ground.  Inexperienced CEOs may have amazing, ground-breaking ideas and new ways to develop and market them, but if they are not effective as either leaders or managers, then they may fall into leaning on personality ethic.  These are the leaders whose individual credibility and identities dominate every aspect of their business, to investors, colleagues, employees, customers, and the public in general.

Without a prevailing independent corporate culture that relies on a collective character ethic and mature organizational integrity, these situations do not make for long-term viable business strategies.  Instead, these companies all too often slip into misconduct, fraudulent practices, and an overall culture of non-compliance.   Risk from regulatory non-adherence, corner-cutting in basic business operational requirements, and other malfeasance is not controlled by the appropriate and thoughtful defense strategies that a compliance program could create, implement, and monitor.

There are a number of examples of companies which grew impressively and then suffered due to insufficient leadership or immature management.  In each case these businesses are known for a prominent figurehead whose personality attracted the press and the public and whose ideas were exciting to the markets and enticing to investors.  However, legal and regulatory inadequacies of these businesses and their cultures have hobbled these companies’ lasting ascent:

  • Apple – Steve Jobs – The ouster of Steve Jobs at the company he created, Apple, led by the mentor he brought on to guide him to the next level as CEO, John Sculley, is the stuff of Silicon Valley legend. While this often seen as an epic example of corporate disloyalty and executive board politics, the more powerful lesson here is for business values and sustainable practices.  At the time Jobs was fired from his own company, emotional intelligence, inner success, and business mission statements were not part of the popular parlance.  Perhaps if they had been, Sculley and Jobs wouldn’t have found themselves permanently estranged: Former Apple CEO John Sculley admits Steve Jobs never forgave him, and he never repaired their friendship, before Jobs died
  • Nasty Gal – Sophia Amoruso: The retail entrepreneur and self-proclaimed “girl boss” may beg to differ with her inclusion in this list, but Sophia Amoruso is a classic example of personality ethic over character ethic.  Amoruso developed a company in her own image, and then turned her image into a personal brand that both transcended and hindered Nasty Gal.  Amoruso is a polarizing personality, and the whimsical approach she embraced in her life may be great for a career as a motivational speaker and writer where people who need inspiration can take a few tips from her for self-development.  However, a business that succeeded due to Amoruso’s successes was also vulnerable to fail due to her failures, without its own corporate identity and developed business culture, and this led to the ultimate undoing of her brand (to be rescued by a larger corporate entity, away from Amoruso’s control), rather than its longevity:  What Comes After Scandal and Scathing Reviews? Sophia Amoruso Is Finding Out
  • Uber – Travis Kalanick – Travis Kalanick’s tenure at Uber started in idolatry around the industry, when everyone with an idea for app wanted to imitate and one-up his path to success. Starting in 2016, however, cracks in the pedestal Kalanick was up on began to show.  Once his public relations woes began, they never ended, even after he was ousted as CEO of Uber for countless issues with the company’s corporate culture for employees, regulatory adherence in critical markets, and legal risks.  All of these problems came out in a powerful confluence at least in part because Uber’s quick rise to the top was enabled by non-compliance via omission at its origins:  Uber Scandal Timeline: Why Did CEO Travis Kalanick Resign? 
  • Thinx – Miki Agrawal – Check out this post for a comprehensive take on the inappropriate conduct modelling of Miki Agrawal and the destructive impact it had on corporate culture at her innovative female hygiene apparel company, Thinx.
  • Theranos – Elizabeth Holmes – Check out this post for a look at the cult of personality created by Elizabeth Holmes at the blood-testing device company Theranos, and the fraudulent business practices and misrepresentations that were enabled by it.
  • Tinder – Sean Rad – Check out this post for a detailed discussion of the emotional un-intelligence that dominated the start-up culture of Tinder due to the influence of its CEO, Sean Rad, and the absence of a burgeoning compliance program to match the booming dating app business.

For an interesting counterpoint, check out the post on Eric Schmidt at Google:  Google is not without its corporate culture challenges, particularly as shown in 2017 by the loud public discussion over diversity and engagement in its ranks and the company’s clumsy and performative handling of this bad publicity.  However, Google has often portrayed Eric Schmidt at the grown-up in the room, not to prevent or obstruct innovation and success, but to steward and support these efforts while still taking care of the underlying business operations must-haves.  Check out this Wired article on how this management structure enabled Google’s development into one of the major digital companies in the world:  At Google, Eric Schmidt Wrote the Book on Adult Supervision

For similar discussions to this one, check out this post on essential compliance tips for small businesses, and this post on challenges faced by start-ups in Silicon Valley and other disruptive industries.

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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.

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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.

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