Hmmm… “Chief Integrity Officer” – What’s in a Title?

by Donna Boehme

Oh my. A “Chief Integrity Officer.” When I spied this idea in my Twitter network today, I must admit, it sent a chill through my bones. And with boatloads of respect to my brilliant friend in trust, Barbara Kimmel (Founder & CEO of Trust Across America #QueenofTrust), I’m afraid I will have to include in this category any idea to create a ”Chief Trust Officer.” And now I’m going to tell you why my gut reaction is a “chill” and not a “thrill.”

To paraphrase the Bard, “What’s in a Title?” As a former CCO who spent weeks 24/7 debating the name of my new function – and thus title (after consultation with my then team and both Oracles), my short answer is; “Everything!” Oh, and the final decision? à Group Compliance & Ethics Officer, which I never regretted for even a nano-moment. My networks have heard me talk about the iterative process of designing my BP program architecture on a giant white board in my new office at the company’s St. James HQ, but before all that were questions of “What’s our name?” and what the several alternatives would convey in terms of (i) mandate, (ii) empowerment, and (iii) global reach/scope. With 100% hindsight, I can now report that “Compliance” was always the first word in the function name because it denoted the power and teeth of the new function, and was the common name of the then-budding profession at the time circa 2003).

We then added “Ethics” for a number of reasons: first, I’ve always regarded “Ethics” as a fundamental and inextricable component of an effective compliance program. And then, it was important to soften and broaden the mandate. One of the Oracles had created the term “Business Practices” for the same reason, and I totally adopted his rationale. At the time, I knew that I would spend my first year just explaining the concept of “Compliance’, and I wanted to give myself some wiggle room. And the notion of “Compliance” all by its lonesome seemed to conjure up a picture of a stark “legal Compliance” exercise of checklists and forms, as many in the DIY Compliance mode seem to pursue.

But what about “integrity”? I love the word “integrity.” It is powerful and meaningful, and at BP we had the great (and nearly undoable) experience of translating it into 34 languages. I/ve already addressed (for years) why “Ethics” is an integral part of any compliance program. In each of these columns or talks, the words “integrity” or “trust” could be easily substituted for the word “ethics.” For the same reasons I have encouraged CCOs not to forget their roles as Ethical Culture Leader.

So now we’ve discussed why titles matter. But another new corporate title? No thank you. As ‪@KaseyIngramJD tweeted: ‪

I agree with that nugget of very sound CCO reasoning, and one more issue: a title as “mushy” and broad as “Chief Integrity Officer” shares much with our own classic title “Chief Compliance Officer” in that it invites all the unfortunate, familiar reactions from others on the corporate landscape: “crabs in the barrel,” “title envy” and an alarming tendency to want to “title appropriate.”

In my career in the wonderful world of compliance and ethics, I have seen more than my share of smug CEOs and GCs who want to claim that THEY are actually the “Chief Compliance Officer” of their company. Ugh. They say this for a few reasons:

  • The higher you go, the bigger the ego. “That title sounds important; therefore, I can do it.”
  • “Why hire a new exec? I know integrity, I’ll take the title.”
  • Chaos loves a vacuum. Any new, big title likely suffers from a lack of definition, i.e. CCO. In a vacuum, other professions and execs think they can define the new role to serve their needs. Sorta like the Legal profession, that covets potential career and employment opportunities, and new business.

My readers know that the profession has spent over 20 years defining itself as a new, independent subject matter expertise (SME) and profession. With true Compliance SME as the fundamental element of the modern Compliance 2.0 model, (a fact increasingly acknowledged by gatekeepers such as the DOJ), let’s consider that job Been There, Done That. We don’t need another 10-year debate, even though we have the winning hand. #ROWRR

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