Meet Jolene Miller... continued from page 25A Long Way…Maybe... continued from page 17employees, both corporate <strong>and</strong>retail. The amendments furtheremphasized the need for ethicstraining for all employees <strong>and</strong>brought the need for such trainingto the forefront <strong>of</strong> senior management<strong>and</strong> our Board <strong>of</strong> Directors,which gave our department a highlevel <strong>of</strong> support for our systemic initiatives.RJ: How do you change organizationalculture to encourage everyoneto act ethically <strong>and</strong> lawfully?<strong>JM</strong>: Change in organizational culturestarts at the top <strong>of</strong> every organization.While every team member isresponsible for acting ethically <strong>and</strong>lawfully, senior management <strong>and</strong> theBoard <strong>of</strong> Directors must hold individualsaccountable for their actions,whether by reward or reprim<strong>and</strong>.RJ: Some people believe that anethics program is only "windowdressing"-areal compliance programemphasizes enforcement <strong>and</strong> discipline,not "doing good." What isyour opinion?<strong>JM</strong>: An ethics program isn't justabout "doing good". It is about providingthe foundation for doing theright thing <strong>and</strong> giving team membersa means to ask questions whenthey are unsure <strong>of</strong> the appropriatecourse <strong>of</strong> action. A strong complianceprogram, including enforcement,discipline, <strong>and</strong> reward, is acritical component <strong>of</strong> an overallethics program. ■enforced consistently throughoutthe organization through appropriateincentives to perform inaccordance with the compliance<strong>and</strong> ethics program…"These requirements are groundbreakingin that they focus on thenecessity <strong>of</strong> an organization toexamine its culture <strong>and</strong> ask thequestion "Do we have a culturewhere doing the right thing is themost rewarding choice to ouremployees?" That's a tough questionto ask, <strong>and</strong> even a harder one toanswer.Now, there is going to be a lot <strong>of</strong>talk in compliance circles about"culture", <strong>and</strong> I imagine that a lot <strong>of</strong>conferences <strong>and</strong> programs will nowfeature that as a topic. In fact, thespeaker following me is going todiscuss that very issue. Again, Iwould remind you <strong>of</strong> 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 development<strong>of</strong> a compliance culture requireslooking at not only the elements <strong>of</strong>your compliance program, but athorough, <strong>and</strong> sometimes painful,examination <strong>of</strong> what is really beingreinforced in your organization, <strong>and</strong>then setting about to craft a behavioralsupport system that trulyembraces ethical conduct <strong>and</strong> regulatorycompliance.Business ethics <strong>and</strong> complianceprograms are no longer the noveltythat they were 13 years ago. They'rehere to stay. If we look at 1991 asthe beginning <strong>of</strong> the formalizing <strong>of</strong>this 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 <strong>of</strong>us who are in this pr<strong>of</strong>ession havean opportunity to grow <strong>and</strong> manageour programs in some very meaningfulways.In writing this presentation, I wasreminded <strong>of</strong> the story about theproud parents <strong>of</strong> a five year oldchild who they believed was thenext Chopin. As luck would have it,a famous pianist was coming totheir town <strong>and</strong>, after much persuasionby the parents, agreed to hearthe boy play. The day <strong>of</strong> theappointment arrived <strong>and</strong> the proudparents brought the child to theconcert hall. The master politely listenedto the boy play <strong>and</strong> turned tothe parents <strong>and</strong> 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 <strong>of</strong> us play the notesvery well. The challenge in thecoming years will be for us to moveonto the next level, to create thatculture <strong>of</strong> compliance within ourorganizations. When we do, we willhave learned to play the music, <strong>and</strong>only then will we have truly come along way. ■February 200522<strong>Society</strong> <strong>of</strong> <strong>Corporate</strong> <strong>Compliance</strong> <strong>and</strong> <strong>Ethics</strong> • (888) 277-4977 • www.corporatecompliance.org
<strong>Society</strong> <strong>of</strong> <strong>Corporate</strong> <strong>Compliance</strong> <strong>and</strong> <strong>Ethics</strong> • (888) 277-4977 • www.corporatecompliance.orgFebruary 200523
Change language