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Compliance and Ethics Officers: A Survival Guide for the Economic Downturn
Written by Jim Nortz   
Tuesday, 13 July 2010 16:51


Even in the best of times, being a compliance or ethics officer is not a job for the faint of heart. In addition to small staffs and big responsibilities, the profession is still so new that most of the people do not even really know what they do or why they are on the payroll. To make things worse, compliance and ethics office budgets are a conspicuous expense on the balance sheet with no obvious return on investment. And, on top of all of that, they’re the ones who occasionally have the unpleasant task of telling senior managers that they cannot do things that they really want to do.

As many in our profession are likely finding out, this difficult job becomes exponentially harder in tough economic times. As management teams go into “survival mode” looking for every possible penny of cost savings, compliance and ethics offices may be looked upon as a luxury that must be eliminated until good times return.

Of course, the irony is that there is no time that a corporation is in greater need of an effective compliance and ethics office than in tough economic times. History has shown time and again that when management feels that enterprise survival is in jeopardy, corners are cut and the motivation to rationalize unethical business practices, if not outright fraud, is at its greatest.

So, as we all fasten our seatbelts for an economic ride unlike any experienced in nearly a century, what can and should compliance and ethics officers do to maximize their chances of surviving, if not thriving, at a time when their services and good counsel are truly needed most?

Plant a Tree, if not Yesterday, Today

There’s an old saying that the best time to plant a tree was 100 years ago. The second best time is now. The same is true for you and your compliance and ethics office. The best time for you to have demonstrated your compliance and ethics officers - surviving economic downturnrelevance to the business was years before the current economic downturn. The second best time is today.

If you have not done so already, it is vital that you invest the time and effort necessary to get in touch with what is happening in the business and the pressures your leaders are facing.


Re-think Priorities

If your company is in survival mode, you must get in that mindset. It is time for you to carefully review your entire program with a critical eye and eliminate anything that is not essential in the short term.

Also, the next time you meet with senior management, leave your usual, marginally relevant compliance and ethics training statistics behind. Instead, lay out what you have done to trim the fat out of your budget and focus your discussion on the company’s top three legal and ethical risks along with your plan for managing them. O


Talk About the Compliance Elephant in the Room

In the coming months there will likely be a steady stream of such headlines as “never say die” business leaders pull out all the stops to avoid failure. Your job is to make sure that your firm is not among them. The only way to do this is to face this issue squarely and make high-level fraud prevention a central part of your compliance and ethics survival plan. In so doing, sit down with your CFO and your outside auditors to make sure you’ve got the support and systems you need to make it real.

There is no way now to know how the current global economic crisis will turn out.  By following the recommendations outlined above, they may play a vital roll in saving many companies from ruin thus furthering the development, sophistication, and institutionalization of the corporate compliance and ethics profession.

This story is available in full at Corporate Compliance Insights.

 

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