Donna Boehme – Compliance & Ethics Professional – September 2014
Donna Boehme is on break; until her return we will be running some of her most popular previous columns.
When I was in Girl Scouts, we used to sing “Kumbaya” around the campfire. Fast forward to 2013, where Kumbaya is now defined in the Urban Dictionary as “blandly pious and naively optimistic.” Still, Kumbaya is what I flashback to when I see some CEOs breathlessly announcing “new values” and others bragging about their latest award for “most ethical company in the universe.”
This is what I call “Kumbaya Compliance.” The CEO issues an edict, maybe a press release, and everyone in the company holds hands in a sing–along to make the company ethical and compliant, just like magic. If this works, why do we even need compliance officers and programs? Shouldn’t the Federal Sentencing Guidelines be shortened to just four elements? Let’s review: (1) management edict, (2) campfire, (3) marshmallows, and (4) Kumbaya.
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