March/April 2009 www.FAOToday.com
March/April 2009 www.FAOToday.com
March/April 2009 www.FAOToday.com
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CEO’s Corner<br />
Embracing<br />
Responsible<br />
Common Sense<br />
This is more in the nature of a blog than a column. I am writing<br />
it at the CRO Summit in Washington, DC, on <strong>April</strong> 23, <strong>2009</strong>,<br />
while listening to a panel of BPO providers discussing the management<br />
of <strong>com</strong>pliance in the era of corporate responsibility.<br />
The CRO Summit series (<strong>www</strong>.thecro.<strong>com</strong>) is part of an offering by CRO Magazine and the<br />
CRO Association. The acronym stands for “Chief Responsibility Officer.” The mission of this<br />
group is the professionalization of an area that subsumes corporate responsibility, sustainability, and<br />
governance risk and <strong>com</strong>pliance.<br />
David Good, chief representative of Tata Sons (parent <strong>com</strong>pany of Tata Consultancy Services) in<br />
North America; Charles Bartels, director of Global Social Responsibilty & Knowledge Sharing at<br />
Manpower; and Suranjan Pramanik, head of Client Services, Manufacturing at Infosys BPO are discussing<br />
the various ways their <strong>com</strong>panies have addressed the rigors of BPO <strong>com</strong>pliance management<br />
in the new world order. Glenn Davidson, managing director of EquaTerra’s public sector advisory<br />
services in the Americas, is moderating the panel, going right at issues like the Satyam scandal and<br />
the need to meet the responsibility requirements of the provider agenda and the client agenda.<br />
It occurs to me as I listen that the world has changed a great deal. We need to live in the era of<br />
<strong>com</strong>mon sense as providers. Where does the role of provider end and whistle blower begin? What is<br />
technically <strong>com</strong>pliant and morally sound?<br />
Responsibility in the financial profession is hemmed in on all sides by AICPA rules, FASB guidelines,<br />
SEC guidelines, and local and national laws. It would seem in the current financial crisis,<br />
however, that the phrase, “plausible deniability” gets too much use. “We did not know,” or “We did<br />
not realize” or “What we did was not technically against the rules, so we were in <strong>com</strong>pliance,” are<br />
<strong>com</strong>mon refrains.<br />
For financial executives, where does <strong>com</strong>mon sense in managing a business <strong>com</strong>e into focus?<br />
When you lend the same $10 to 40 people, that is more than “leverage.” It is like a weird rewrite of<br />
the Mel Brooks play, “The Producers,” where the characters have a 400 percent equity interest in<br />
the same Broadway show. Let’s not forget that show ends with Max Bialystock in jail.<br />
The role of financial executives is not only measurement and recordkeeping. It is also managing<br />
and discerning dishonesty in the business. The <strong>com</strong>ing storm of “re-regulation” as some are calling<br />
it is the result of the bad acts of a few leading to the punishment of the many. Common sense is a<br />
cornerstone of responsibility. Most of the time, when people are doing something wrong, they know<br />
it but rationalize it away, or decide to do it anyway.<br />
Should the FAO provider be made an ac<strong>com</strong>plice if they manage <strong>com</strong>pliance, or be culpable if<br />
they do not inform the proper authorities? In the case of law breaking, the answer is simple. Yes. If a<br />
provider sees law breaking, they need to inform the <strong>com</strong>pany’s chief <strong>com</strong>pliance officer or the chair<br />
of the audit <strong>com</strong>mittee. In the case of behavior that is irresponsible but not so clearly illegal, they<br />
need to discuss with the chief financial officer the behaviors that concern them.<br />
Merely keeping the books is no longer enough and is not in the best interest of the shareholders<br />
who are paying that provider’s fees. As for financial professionals, we live in a new era of responsibility,<br />
and all of your internal departments and external resources now have to ask not only what is<br />
<strong>com</strong>pliant but what is sensible, what is responsible, what is sustainable, and what is in the best<br />
long-term interest of our shareholders, employees, and customers.<br />
Elliot H. Clark, CEO<br />
4 FAO Today <strong>March</strong>/<strong>April</strong> <strong>2009</strong><br />
CEO: Elliot Clark<br />
eclark@crossingmedia.<strong>com</strong><br />
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