Where to begin: The Wall
This is my first work in the blog space and so I will begin with a brief that shares a little of my foundational perspective on compliance and introduces me and my style. Future efforts will likely not be so casual in form or substance but I am laying some groundwork here, so bear with me. There is plenty of substantive material to cover in future blogs.
I am going to talk about compliance today through the lens of my experiences growing up in a small town. There may have been certain drawbacks to small town life in the 1900s (as my children call it), but there was plenty of wisdom as well. Along the way I learned some important life lessons that have served me well in my various compliance roles. One of those foundational elements has been the concept that you do the important jobs right the first time.
I grew up in a New England farming town, with farmers who were immensely practical and thoughtful. There was always so much work to do on the farm that wasted effort was viewed critically. Having to do rework was the worst offense. When it was time to work an important project there was considerable preparation and energy that went into reviewing the work plan to be certain it accounted for all critical elements; walking over the work site to identify potential problems; checking the needed tools to ensure that each was in good working order; and looking at the upcoming weather (always important to farmers). Once the project started it would become the farmer’s priority for the time period required.
My favorite task that falls into this bucket is the building of a stone wall. New England is littered with them. I hike all over the region and you come across old stone walls in the most far-flung places. Some are informal piles of rock made from “two-handers”, typically plowed up from the field and moved off to the side. They would later be organized into a wall and would demarcate a grazing field from a crop field. Others were more formal, marking a boundary between properties. These were the walls that I enjoyed the most. Works that were carefully crafted and meticulous in construction. These walls were important boundary markers and the ones most subject to public scrutiny and comment.
I have seen some old stone masons working these walls in the past. A well-built wall started with a trench dug below ground and a foundation material put down to keep the bottom layer in place and secure. Every other level is built on that foundation. Those next layers are also, typically, constructed without the benefit of mortar or cement. Just rocks closely interlaced in what, to the untrained eye, may seem a random pattern but to the mason is a thoughtfully created design intended to lock in the materials and to stand the test of time.
Back to compliance. I would conduct training on compliance and ethics for internal clients and, as part of my presentation, I would show them a slide with images of two walls. One looks like that random wall I mentioned above: the one thrown together for the internal benefit of the farmer only; the other looking more substantial and well-built. The first wall is practical and serves the farmers needs. He, and his hands, all know why the wall is there and the purpose it serves. It can also be mended or moved (not an easy task) to account for the needs of the farm. The second, is public-facing. It serves the needs of the farmer and his community. It is also a representation of his commitment to what the wall represents. It takes more time to construct that wall and considerable effort to repair and maintain it, but a farmer would never let that wall fall into disrepair.
Our compliance programs are like those walls. For each element (or wall) has its purpose and is built according to the needs associated with that purpose taking into account: (i) the time and effort required to complete the task; (ii) availability of necessary resources; and (iii) the other priorities of the business. It is important that we all build our compliance programs on these same principles. Does the wall (or control) meet the need of the business? Are elements flexible enough to change with the business? Do we know which walls are fundamental to our business’ operations and reputation? When building your “wall” have you walked the site (engaged key stakeholders and run a risk assessment); checked your tools (validated that you have the needed resources – both personnel and materials); and verified the weather (cleared the plan with senior leadership and supporting functions)?
Success can be had if you have done the background work, obtained a commitment from key stakeholders, and been assured the resources to support the plan for the duration of the project. With the proper foundation and construction your program will be helpful, practical, respected by those inside and outside your organization. And, you can know that your program (wall) will stand the test of time. No shortcuts, only thoughtful planning, hard work, and a commitment to the final product will see you achieve your goal.
