Compliance Mindset

What means a good Compliance Mindset? Is it more than the presence of a regulatory expert? Is it all about doing the right thing?

Compliance Mindset

As you have experienced it, does top management consider compliance to be an essential corporate fundamental for the company? Were you able to convince your clients at the top management level to adhere to this mindset?

Bénédicte: I really think that compliance needs to be rooted in the management mindset more broadly than at the top level only. Without the top-down and bottom-up adherence and contribution of all employees (and not only the managers – top managers are also employees, and they are not above internal rules), compliance can’t be a corporate fundamental lived out in the culture of the company.

Have you ever heard from a top manager “Compliance matters for me. I want it for my organisation.”?

Bénédicte: I have clearly heard this statement publicly, not only in the private office of the top management, but also during a public conference where a lawyer came with his client sharing a difficult experience of a DOJ inspection after a compliance violation. This time, I clearly could see that theoretical introductions of internal guidelines made by top management were concretely lived out and commented on with authenticity. Indeed, we all know the gap between a written tone from the top and effective implementation in the field. Unfortunately, I confirmed that the carrot and stick is a reality. Anticipating risks with a habilitated compliance organisation empowers the business and the strategy of the company on a long-term perspective. Should we wait for an incident to implement compliance?

How would you describe your relationship to the top management?

Maria: It was a trustful and cooperative relationship, which enabled me to reach the expectations I had as an in-house compliance manager. Of course, it doesn’t mean that it was a given and that I didn’t disagree with the position of the top management in some specific cases.

How do you see the role of a Compliance Officer?

Bénédicte: The compliance officer should not be restricted as the exclusive contact person for the legal and other support-function departments. The officer needs to act as a hub working with all units to get to know the risks on the field and propose appropriate corrective measures. Having a trustful and collaborative relationship with all management levels remains of paramount importance, of course.

You mentioned that Compliance should be a lived-out company culture. So, what do you do to get a lively awareness and communication of compliance in the organisation?

Bénédicte: The compliance officer is a human being speaking to employees who are also human beings – so please remain human in your communication! Meet the employees personally, and do not only use tools for doing compliance. A tool without a real face and trust in the compliance officer is not empowered.