(This is a guest post from Roy Snell. This post originally appeared on the SCCE blog.)
By Roy Snell
We have a problem and we are going to fix it.
For those of you are too young to young to know, the Pointer Sisters were fantastic singers from a bygone era. The pointer sisters you are more familiar with now are those that point to ethical or regulatory problems but do little to help. Ethicists point to human failure, tell you how terrible it is and advise us to be ethical. Risk points in a direction and says “I advise you to look for problems over there first.” Auditors points and says, “The problem is right here.” Investigators point to the evidence that proves there is a problem. Lawyers point to the law that says that what was done was illegal. The professional term for these services is “advisory.” They point and advise people to fix a problem. Many times the advice is taken and the problem is fixed. Advising works sometimes. But all too often, particularly on very big problems, advising is not enough.
People advised leadership at Penn State University to do something about a known pedophile and went back to their office. Ten years later society did more than advise PSU, they fixed the problem. Enron was advised of their problems. After it was too late to save employee pensions, society fixed the problem. Walmart has an alleged situation where people say they had a potential bribery issue several years ago. The evidence that has been released suggests that there was advising and pointing at the problem. In all these situations the pointer sisters were doing a good job of pointing but they were not fixing. In their defense they would tell you they didn’t have authority. They would say they pointed but no one listened. They would say that it was not their responsibility. And frankly I would completely support that defense because that is how their jobs were defined. Society decided we needed more than finger pointing, advising and most problems being fixed. They wanted all problems fixed.
They wanted someone to have the authority, responsibility, and the independence to prevent, find and fix regulatory and ethical issues. Coincidently that is exactly what the job description of a compliance officer is. The compliance profession is here because those who came before the compliance officer often pointed and advised but did not fix all the problems they found. So society invented the compliance officer role and the job definition includes fixing all the problems. Some don’t want the compliance officer to have that authority, responsibility and independence. Let’s stop talking, hoping, theorizing, pointing and advising and do something. Let’s give the compliance officer authority, responsibility and independence. Let’s revitalize the business community’s reputation.