JM - Society of Corporate Compliance and Ethics

February 20054by Bill PracharEditor’s Note: Bill Prachar has over thirty meetings of ethics and complianceyears experience in Compliance, Ethics organizations including the HCCA,and Corporate Governance. Bill is an the Conference Board, the DII, theattorney practicing with the Compliance EOA and most recently the SCCE.Systems Legal Group (CSLG). Because There is a common theme, orBill has an extensive business, as well as maybe better stated, a commonlegal background, he specializes in the frustration that inevitably turns up atpractical issues associated with developingand implementing effective ethics described as the Rodneythese gatherings - I think it is bestand compliance programs. Email: Dangerfield "I don't get no respect"bprachar@cslg.comsyndrome. Maybe that's a bit of astretch, but the frustration is mostThis is the first of what I often expressed, "How do we earnhope to be a series of a seat at the table."columns addressing issuesfaced by compliance and ethics professionalsas they go about their high-profile corporate scandals,With all the recent excitement overdaily work trying to build and maintainstrong compliance cultures in do-it-right cultures rightfully seethose of us struggling with buildingtheir organizations. The columns what we are trying to accomplish aswill be based on observations and very important. It's a good thingexperiences gathered during my 30 we do. The problem is, it isn't perfectlyclear that everyone in ouryears in organizational complianceand my involvement in business organizations sees what we do inethics since the early 1990's. They quite the same way. It's not thatwill express my opinions, which of others don't believe in ethical andcourse means, as my spouse and compliant business conduct, it's justdaughter remind me from time-totime,there is a good chance I'm out their business tasks, and havethat they've got a lot to do to carrywrong, or at least partially off base. little patience for added bureaucracy,particularly when it comes fromI hope the column will generatediscussion and I encourage readers the corporate office. Like lawyersto email me their thoughts, pro or and HR folks, we're tolerated, butcon, on the topics I tackle. We will not much more. (Of course add atry to run responses (with permissionof course) that offer alternate Agreement to the mix, and the levelsmall CIA, or DOJ Administrativeviews or solutions to those I of tolerance, at least temporarily,express. That said, here goes … goes way up!)Over the last 10+ years I haveattended and spoken at numerousI believe there are two solutions tothis problem. The first is to adjustexpectations to a realistic level.The second is to recognize that, likeevery other sub-part of your organization,the ethics and compliancefunction supports business objectives,and, accordingly, to makesure that the function acts like abusiness unit.With respect to setting expectations,it is important to remember that ifyour organization fails in its businessobjectives, there are no jobsfor anyone, including E&C personnel.As a consequence, the job ofE&C will never have the same statusin the organization as those functionsdesigning and executing thebusiness plan. The heroes in businessare those who make money.That's OK and it's not going tochange soon. We E&Cers just wantto make sure the money is madeethically and in full compliancewith the law. Ours is a job done inthe background, and we need toaccept that reality.Most important for earning a seat atthe table is recognizing the need tobehave like every other part of thebusiness organization. The moreE&C people are seen as "businessSociety of Corporate Compliance and Ethics • (888) 277-4977 • www.corporatecompliance.orgBILL PRACHAR