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FCPA Compliance Report

Tom Fox has practiced law in Houston for 30 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.
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Nov 15, 2017

What if you could multiple the impact and effectiveness of your compliance program throughout your company? That would be a great boon to any compliance practitioner and compliance program. It is also something that is very possible by considering a 360-degree view of communications in compliance using multipliers. 

Liz Wiseman is the co-author with Greg McKeown of Multipliers: How the Best Leaders Make Everyone Smarter, which is a book about the various types of leaders. They focus two different types of leaders, Diminishers and Multipliers. Multipliers are leaders who encourage growth and creativity from their workers, while Diminishers are those who hinder and otherwise keep their employees’ productivity at a minimum. 

These techniques not only beneficial for every Chief Compliance Officer to use as a business leader within your organization, but also for every compliance practitioner to more fully operationalize corporate compliance programs. The also help you to understand more fully the concept of 360-degrees of communication because in every interaction you can multiply the power of your communication by using a variety of simple and even straight-forward tools and techniques. 

Multipliers increase, often exponentially, the intelligence of the people around them through communication. They lead organizations or groups that can understand and solve hard problems rapidly, achieve their goals, and adapt and increase their capacity over time. On the other hand, diminishers literally drain the intelligence, energy and capability from the employees or team members around them. They lead groups that operate in silos, find it hard to get things done, seem unable to do what’s needed to reach their goals. 

Multipliers break down into five disciplines in which they differentiate themselves from diminishers. The first is the Talent Magnet, who attracts and optimizes talent; the second is the Liberator, who creates intensity that requires an employee’s best thinking; next is the Challenger who extends challenges by having others do the hard lifting so that they can stretch themselves; next is the Debate Maker who facilitates a debate between his or her team which leads to a decision improving a process or issue; and finally is the Investor, who instills ownership and accountability with his/her employee base. Interestingly Wiseman believes that multipliers increase efficiency and productivity by two times. 

Diminishers also break down into five different prototypes. They are the Empire Builder, who is only interested in collecting very talented people around themselves so that they look good; next is the Tyrant, whose name is almost self-disclosing but ruins all those around them with their insistent criticisms; next is the Know-it-all who give directives simply to showcase how much they know limiting what their teams can achieve to what they themselves know how to do. This means the team must try to deduce, literally in the dark, the soundness of the decision instead of executing it; and finally, there is Micromanager, who generally believes they are only person who can figure something out and approach execution by maintaining ownership, jumping in and out of a project and reclaiming responsibility for problems which they have delegated. Diminishers usually reduce efficiencies by up to 50%. 

Wiseman presented several ways that a leader could use multiplier effects and I found many of them would work particularly well for the compliance practitioner who is working to operationalize a best practices compliance program. This is particularly true because it is through persuasion that compliance works best by getting other corporate disciplines to embrace compliance. 

Some of the specific multiplier techniques are to identify not only what the skills are for those on your team, but also what comes easily and natural to them. By doing so you can more effectively utilize their talents in implementing a compliance regime. Interestingly you can get employees to stretch through a technique called ‘supersizing’ where you give someone a task that may be “one size too big” for them, but allows them to grow into it. This is certainly applicable when working to operationalize compliance in business units outside the United States which may only have been dictated to previously but where not involving in doing compliance. 

As the CCO or compliance leader working to more fully operationalize your compliance program, you should work to limit your direct comments to a minimum going forward. This will allow the non-compliance team members to not only stretch themselves but also allows for more impactful intervention when necessary but the simple fact is you are intervening less. Louis Sapirman, the CCO at Dun & Bradstreet said that while he holds the office, he is not the face of compliance at the company. It is him employee base. He has literally multiplied the influence of the compliance function both inside and outside the company in this manner. 

Mistakes are going to happen in any implementation. The same is true when you are operationalizing your compliance program. To overcome this there are a couple of strategies. The first is to talk up your mistakes within the team for debriefing and analysis. The second is to actually make room for mistakes (think of a sandbox) where your team can experiment, take some risks and recover from the mistakes. 

I found her next point fascinating, which was to lead by asking questions. Every question is answered by another question. Her technique of leading with questions works with all five categories of multipliers. The reason it is so successful is that people are smart, the not only want to get things right but they want to build and eventually they will figure out how to do it. It is not simply a case of getting out of their way. It is about guiding them with your compliance expertise to come up with not only the right answer but a solution which will work. 

Now imagine applying this leadership technique as you are trying to more fully operationalize your compliance program. If you take this approach of leading by asking questions, you not only guidance the functional unit but you get greater buy-in to the entire concept and process as it becomes their process. The non-compliance team may design it and have ownership over it. 

Wiseman concluded by challenging each of us to multiply our influence to make those with work with and even work for better. You can use these skills to more fully operationalize your compliance program. If you do so, you will not only fulfill the requirements of the Department of Justice, laid out in the Evaluation of Corporate Compliance Programs, you will bake compliance into the DNA of your company by making it a part of the way you conduct your business. 

Three Key Takeaways 

  1. Multipliers are leaders who encourage growth and creativity from their workers.
  2. Diminishers are those who hinder and otherwise keep their employees’ productivity at a minimum.
  3. Multiply the influence of the compliance function both inside and outside the company in this manner.

This month’s podcast series is sponsored by Dun & Bradstreet.  Dun & Bradstreet’s compliance solutions provide comprehensive due diligence reporting and analysis to reduce your risk of working with fraudulent companies by accessing a company’s beneficial ownership, reputation risk and more.  For more information, go to dnb.com/compliance.

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