CCO Rule #2a – Sometimes Even A Great Plan Needs a Tweak

Donna Boehme

Once, in one of my CCO roles, we had a carefully conceived and detailed plan and timetable to roll out our company’s first global Code of Conduct to 100,000 employees in 100+ countries over a period of six months. The plan was a product of months of brainstorming, conceptualizing, and hard work by my team, and had been “socialized” with our Board, senior management, compliance ambassadors, and functional partners throughout the organization. I remember we shared our vision and plan (including the integrated workstreams for focus groups, translations, compliance ambassador network and training, training scenarios, launch videos, and simultaneous launch/distributions throughout all our jurisdictions and time zones) at a few compliance conferences so that others could benefit from our work. The project involved many functions, businesses, personnel and experts across the globe.

But, at the 11th hour, a meeting with one of our functional partners made me realize that our planned rollout was missing one important step. Even though all of this work had been tied to a firm launch date (let’s call it May 1) I realized that none of our functional partners had been adequately prepared or trained to perform their potential roles in the Code roll-out! What if the HR department received calls or questions about parts of the Code where it was “risk-owner”? Would they be ready to respond? Did they have a solid understanding of our overall compliance program and the different ways in which employees would be able to ask questions and report concerns? We had envisioned a seamless rollout with every manager “singing from the same hymn sheet” so that our employees would receive a consistent unified message and information from all involved. We were appalled to realize this gap in our plan – which we realized in a hastily called strategy meeting could cause months of our team efforts to fail or result in major disconnects and confusion!

What to do? A knee-jerk reaction might have been to say “well, all our plans are set, and tied to a firm launch date – and all blessed by our Board!” or “this is written in stone!” But of course the idea of failure was an absolute nonstarter. Thus, CCO Rule #2a noted in the title above is important. We decided to amend our plan consistent with CCO Rule #4: “There is an appropriate solution to every problem” and CCO Rule #3: “Always try to do a task for more than one reason.”

Our solution was to create a two-month “soft launch” phase, during which we would systematically take our Board, management, compliance ambassadors, and functional partners through a “soft launch” version of the Code rollout using all our actual launch tools – tailored to each audience depending on the role they were expected to play. And I’m happy to report that the soft launch phase of our plan not only closed the gap we had identified, but also resulted in a number of additional benefits:

  • My team, working to deliver the soft launch to each of their constituencies, became practiced, skilled, and familiar with all our key messages.
  • We were able to use the feedback from our Soft Launch to greatly improve the launch tools.
  • Since each member of my leadership team was assigned to liaison with an important function, the soft launch created a platform to develop better working relationships and identify areas where we needed to clarify issues/accountabilities and respond further.
  • In the aggregate, the soft launch generated a true organic “buzz” and excitement throughout the company, as employees were hearing that their Code launch session would be dynamic and great!

Shout out to CCO Rule #3 (the Joe Murphy Rule)!

In the end, we were very pleased to learn that an independent PR/Marketing vendor had named our global Code rollout as the “best” global initiative they had ever reviewed at a company, and suggested that it be used as a model for future global projects. The sweet irony of this outcome is discussed here.

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