JM - Society of Corporate Compliance and Ethics

Meet Jolene Miller... continued from page 25A Long Way…Maybe... continued from page 17employees, both corporate andretail. The amendments furtheremphasized the need for ethicstraining for all employees andbrought the need for such trainingto the forefront of senior managementand our Board of Directors,which gave our department a highlevel of support for our systemic initiatives.RJ: How do you change organizationalculture to encourage everyoneto act ethically and lawfully?JM: Change in organizational culturestarts at the top of every organization.While every team member isresponsible for acting ethically andlawfully, senior management and theBoard of Directors must hold individualsaccountable for their actions,whether by reward or reprimand.RJ: Some people believe that anethics program is only "windowdressing"-areal compliance programemphasizes enforcement and discipline,not "doing good." What isyour opinion?JM: An ethics program isn't justabout "doing good". It is about providingthe foundation for doing theright thing and giving team membersa means to ask questions whenthey are unsure of the appropriatecourse of action. A strong complianceprogram, including enforcement,discipline, and reward, is acritical component of an overallethics program. ■enforced consistently throughoutthe organization through appropriateincentives to perform inaccordance with the complianceand ethics program…"These requirements are groundbreakingin that they focus on thenecessity of an organization toexamine its culture and ask thequestion "Do we have a culturewhere doing the right thing is themost rewarding choice to ouremployees?" That's a tough questionto ask, and even a harder one toanswer.Now, there is going to be a lot oftalk in compliance circles about"culture", and I imagine that a lot ofconferences and programs will nowfeature that as a topic. In fact, thespeaker following me is going todiscuss that very issue. Again, Iwould remind you of one thing-it'sall about the behavior. This time it'sabout management's behavior.Ever hear the saying,"Management's actions are so loudthat the employees can't hear whatthey're saying?" The developmentof a compliance culture requireslooking at not only the elements ofyour compliance program, but athorough, and sometimes painful,examination of what is really beingreinforced in your organization, andthen setting about to craft a behavioralsupport system that trulyembraces ethical conduct and regulatorycompliance.Business ethics and complianceprograms are no longer the noveltythat they were 13 years ago. They'rehere to stay. If we look at 1991 asthe beginning of the formalizing ofthis process, then we are looking atan organizational activity that isentering its teen years. A transitiontime from immaturity to maturity.With the new changes in theGuidelines supporting us, those ofus who are in this profession havean opportunity to grow and manageour programs in some very meaningfulways.In writing this presentation, I wasreminded of the story about theproud parents of a five year oldchild who they believed was thenext Chopin. As luck would have it,a famous pianist was coming totheir town and, after much persuasionby the parents, agreed to hearthe boy play. The day of theappointment arrived and the proudparents brought the child to theconcert hall. The master politely listenedto the boy play and turned tothe parents and quietly said, "Yourchild plays the notes very well, butin order to be great, he will have tolearn to play the music."That is where we are today withmost corporate compliance programs.Most of us play the notesvery well. The challenge in thecoming years will be for us to moveonto the next level, to create thatculture of compliance within ourorganizations. When we do, we willhave learned to play the music, andonly then will we have truly come along way. ■February 200522Society of Corporate Compliance and Ethics • (888) 277-4977 • www.corporatecompliance.org