In the ever-expanding universe of corporate governance and compliance, we are constantly reading of “best practices” recommended by one expert or another. They tend to be somewhat sterile, repetitious, and obvious. A book full of such insights, while important, can be a very dull read.

It is certainly true that company executives or managers who zealously follow “best” practices will become better at their jobs and help their companies, and if properly documented by those individuals such sterling habits can promote bonuses and career advancement. We are not here to denigrate that which has been declared “best.”

My list is not exclusive by any means, and may reflect heavily on my background as a lawyer, with prior prosecutorial stints with the DOJ and SEC, and as an in-house lawyer for a large public company. After reading mine, I encourage you to write one for yourself, draw upon your own experiences, and be honest. In the process, take a hard look at your own company and the challenges and risks it faces today, and see if you can’t identify a “worst practice” or two in your organization.  Here’s my list:

• Worst Practice One: Always Believing “The Smartest Guys in the Room”
• Worst Practice Two: Allowing Strategic Planning and Risk Management to Become Problem Avoidance
• Worst Practice Three: Denigrating, Underestimating, or Infuriating Regulators
• Worst Practice Four: Investigating, Documenting, and then Ignoring Problems
• Worst Practice Five: Failing to Make Your Outside Auditors Uncomfortable

This is my short list of “worst practices.”  More important is what is on your list. Indeed, your company should consider having every top manager make their own list, and deliver it to some designated officer who can decide if action is needed. The successful corporate compliance program must be a pro-active, aggressive and occasionally uncomfortable search for the worst, not just the best, practices.

This article is available in full at Corporate Compliance Insights.