It Was My Idea!

by Donna Boehme

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#EthiTweeps → Just saw this great tweet:
NOTHING is more FUN than doing what people say you can’t do! – @KimGarst

So thank you Kim, new #EthiTweep, this column is for you!

Every CCO and Compliance professional has his or her own story to tell in this category, so here’s one of mine:

In one of my early CCO roles, as part of rolling out the company’s first global Code of Conduct, I set a key goal of delivering a hard copy to every individual employee. Within days I was sitting in a meeting with the company’s top HR exec, who told me bluntly and dismissively: “Good luck with that, because we don’t even know who and where all our employees ARE!”

And then I was treated to chapter and verse of a diatribe on battling unmerged HR systems that didn’t “talk to each other” and detailed examples of past debacles. And as we all know, HR is the “beating heart” of any organization, and no CCO can fully achieve their mission without a solid partnership with a willing and empowered HR team. I usually add “high performing” to that description, but, you get the drift, right? And, oh yeah, also sitting in that meeting parroting every “Youcantdoit” statement was a well-paid Marketing/HR vendor/Wizard of Smart. Hold that thought.

Let’s fast-forward a few years. Here’s what our team (and our enabling partners) delivered against our goal:

  • Hard copy of Code, mailed or otherwise delivered, to every individual employee worldwide;
  • Translated Into one of 34 languages;
  • Each employee attended unique interactive “awareness session” led by respected leader and tailored to that group;
  • Full participation by a global Compliance and Ethics leader network (established, trained, and coached by the Compliance team);
  • Rated 99% effective by Marketing/HR Vendor against all global distributions in organization;
  • Vendor’s Report: “should be analyzed as a ‘model’ for future projects”; and
  • Soon after, Vendor’s website prominently features Code rollout and its own role in the “great success.”

This is why, as per the last bullet above, Compliance can measure its success rate by noting just how many parties ultimately take full credit for its ideas and work. I call that “The Evolution of a Compliance Officer’s Idea”


This is why I am known to advise #EthiTweeps and clients that designing and implementing a robust compliance program is definitely a “marathon” and not a “sprint.” The hard-working CCOs who hang on to “Stage 3” may just be rewarded with chants of “It was my idea!” It could – and does – happen! #Compliance2.0ontheRise.


This post first appeared on the SCCE Blog.

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