The CCO as Ethical Culture Leader

The CCO as Ethical Culture Leader

Donna Boehme – Ethikos – February 2014


“Tone at the Top”—I’m over it.

At one point, circa 2002, following the scandals of Enron, Worldcom, Tyco, and the rest of the corporate accounting fraudsters, the idea of the CEO and other senior leaders setting “tone at the top” as workplace role models sounded ground-breaking, even inspirational. What better way to demonstrate the behavior expected of every employee in the organization, from C-suite on down, than leaders who lived the stated values—through words and action—of the company? But now, after CEOs have spent well over a decade hearing governance and ethics commentators tout “tone at the top” as the magic cure-all for a multitude of corporate sins, the phrase has become nearly meaningless. It’s up to the chief compliance officer (CCO) to change that.

Earlier this year, Michael Volkov, former federal prosecutor and good friend to the compliance profession, committed an act of near blasphemy in his column “The CCO—not the CEO—Creates an Ethical Culture. The words “bloviating,” “hot air,” and “Kool- Aid” jumped off the page. It was enough to get all the corporate governance experts’ collective knickers in a wad.

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