Compliance is a horrific brand – why don’t we change it?

In one of my earlier posts I have written about the “brand name” of the compliance department and why I think the words “ethics” or “integrity” should be part of it. (I meanwhile prefer “ethics”.) A few days ago I heard Christian Hunt from Human Risk talk about it in a recent episode of the All Things Risk podcast and he expressed thoughts going into a similar direction. The label you put on the compliance function fundamentally determines the way this function and the people working in it are perceived by the rest of the organization. Perception of compliance creates expectations and attitude towards the function. Adding “Officer” to the job title only serves to make things worse. “Compliance Officer” sound so much like a person you’d rather avoid any contact with if you can, because he may be after you to put you in handcuffs. And a “Compliance Manager” is likely to be perceived as responsible for compliant business outcomes, even though she doesn’t really “manage compliance”. (See also “Risk Manager”…)

The branding affects also the role-identity, sense of purpose and consequently the behavior of the people working in the compliance function, because the department name and job titles as “identity badges” give them a sense of meaning, purpose and value. Just as giving an employee a more senior-sounding title can make them act more responsibly by making them feel happier at work, a “Compliance Officer” is more likely to act like a policeman than a “Compliance Business Partner”. A “Compliance Manager” is more likely to want to approve or reject requests from the business, while at the same time lamenting a lack of (risk, compliance…) ownership by the business.

The profession (and consultants) have recognized this and stressed the importance of developing business partnering skills amongst its members. But what about the simple step of renaming the function? We have seen it in personnel departments who have changed their name (and their identity, purpose, mission statement) from the management of “Human Resources” or “Human Capital” towards being in the business of “People & Organisation”. (And of course they already had “Business Partner” as job titles before.)

When we made that change for HR in my organization, I jokingly said to my colleague, the Head of Legal, that he should change his department name into “People & Laws” and I would change mine into “People & Rules”. The thought has kept resonating within me.

My corporation has changed the name of the function on a global level into “Ethics, Risk & Compliance” and integrated the global Risk Management function (under the name “Risk & Resilience” – again an interesting new branding implying a new perspective on the risk function’s purpose). My thought on this was that the order – Ethics, followed by Risk, followed by Compliance – is actually the right one for one unified core competency of the function: decision-making. Starting with ethics and values, considering the risks and – as an outcome rather than a process – being compliant. It’s all about making good decisions. In the “Ethics & Compliance” part, we are focussing on and giving trainings for developing skills in “values & principles-based decision-making” (VPBDM) whereas our colleagues from “R&R” are driving “risk-based decision-making” (RBDM) or “smart risk taking”.

So what about putting a new brand on the function that avoids the connotations carried by “Compliance” and “Risk” and gives more sense of purpose than “Ethics”? What about “People & Decisions”?

(One thing I have planned for this year is to at least try and change job titles in my team into some kind of “Business Partners”. Let’s see how this works for a new role-identity a snd sense of purpose.)

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