One More 2016 Resolution for CCOs


by Donna Boehme

It’s only just April and I have one more resolution to add to my Top 5 2016 Resolutions List for CCOs (and of course my dear #EthiTweeps):

6. Develop and treasure your networks

I’ve always advised newly minted CCOs to constantly develop and build their networks – whether on social media, in-person meetings, or friendly professional email correspondence. And those of you who have read Kristy Grant-Hart’s excellent book “How to Be a Wildly Effective Compliance Officer” know she has an entire chapter dedicated to this topic.  The last few weeks of the Mega-UNAOIL scandal have proven to me the undeniable worth of this last resolution. I now realize that my networks are so broad and so well populated that little of note happens in the Compliance and Ethics world that I don’t hear about.

This earth-shattering Unaoil bribery scandal is a perfect validation of my networks.  When the story broke, my networks exploded with the news. In fact, the huge number of comments I received – and am still receiving – from the bright and connected professionals in my networks ranged from “have you seen this?” to “what is your takeaway?” to others so snarky I can’t safely repeat them here. In fact, as my Twitter networks have seen, the one word most of my compliance friends love the most from this story is “wanker” (a British pejorative used by one member of the Unaoil Bribe Factory to dismiss the hapless “certifiying organization,” Alexandra Wrage’s TRACE International). I don’t know why that part of the story struck me as so hilarious, whether it was my years living in England (soaking up the British sense of humor), or simply envisioning that conversation taking place as described!!

A second newsworthy item came courtesy of my Antitrust Compliance network, which told me that Brazil’s Council for Economic Defence (CADE) had just released guidance for compliance programs here.  The guidance includes a recommendation that the Compliance function be given “appropriate resources” and “independence” in order to “empower” the function – which gives international credibility to the emerging Compliance 2.0 model. Today Brazil, Tomorrow, the World! (or at least, the OECD). Wouldn’t want to have missed that one!

Simply put, my main takeaway is that my networks see and know all, such that I could be on a two-week holiday on the windward side of Oahu and still not escape knowledge of these developments (and what my networks think of them)! And of course, the bonus is that I now have the topics for my next three blog posts/columns. Thanks, #EthiTweeps! You’re the best!!


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