www.corporatecompliance.org +1 952 933 4977 or 888 277 4977
by Joe Murphy, CCEP, CCEP‑I
THE LAST WORD
The Sales VP & the CECO
You are the new sales VP, and you need your company to sell successfully. Here is your plan:
· A 15-page booklet (with pictures!) on
why sales matter, posted on the Internet
· Training for the sales associates on why
sales matter, with a very brief “executive
summary” for the top salespeople,
because they are so busy
That’s it! No checking, no
accountability, no incentives, no
follow-up, no management steps.
Just a booklet and some training.
Your sales results? Nowhere!
Yet to many, this formula
for failure is exactly how they describe
compliance and ethics programs—codes and
training. Does it work for sales? No. Does it
work for managing business objectives? No.
Can it work for compliance and ethics? What
do you think? If you wouldn’t use it for any
other management purpose, why use it for
compliance and ethics?
Yet from the beginning of our field,
people constantly have talked about what we
do as codes (or policies) and training. This
column was, in fact, triggered by my reading
yet another article (this one about antitrust
compliance) that begins by describing an
antitrust compliance program as a “policy”
and then launching immediately into a
discussion of training.
Compliance and ethics programs are
really two things:
· Management commitment to do
the right thing
· Management steps to make
It is not, and cannot be, a policy. A
policy, on its own, does absolutely nothing.
Nor can it rely merely on training. Human
motivation is complex. Most corporate crime
does not occur because a perpetrator simply
lacked training. Certainly training has great
value, if done well. But training alone is
no more effective in preventing corporate
crime than it would be for driving any other
What does it take to effectively promote
compliance and ethics? The same tools
managers use to accomplish anything
important in an organization. Where
can you find a good list of those tools?
Surprisingly, in a brief document issued
by the government—the steps listed in
the Federal Sentencing Guidelines for
Consider just some of those points: have
management committed and supporting
the effort. Put a high-level person in charge.
Use incentives. Apply discipline. Check
what is going on. Be careful who you hire
and who you promote. Check to see how
each part is working. Have standards and
checks on what people are doing. Use these
steps to mold a supportive culture. Look into
any indications that something is wrong.
And yes, as part of this, have a policy and
How can you be effective as a compliance
officer? Maybe start by observing what makes
any manager effective and what tools they
use. And read the FSGO very carefully. ✵
Joe Murphy ( firstname.lastname@example.org) is a Senior Advisor
at Compliance Strategists, SCCE’s Director of Public Policy, and
Editor-in-Chief of Compliance & Ethics Professional magazine.