A quick search online for public compliance issues such as data breaches reports CEO responses range from resignations to tackling issues with confidence. In a world where compliance issues seem inevitable, how a CEO tackles compliance issues can make or break a career. A top notch CEO takes responsibility for corporate compliance, keeps the Board of Directors apprised of both compliance strategies and issues, and requires management’s teamwork daily to mitigate compliance issues. This blog will summarize six important components of a successful response to compliance issues.
I cannot overemphasize the importance of preparation. In order for a CEO to successfully tackle a compliance issue, the CEO must lead the entire management team through extensive preparation process to development your compliance program including but not limited to policies and procedures for compliance rules, education, monitoring, auditing, and issue response. The rest of the items rely on this fundamental and sometimes seemingly overwhelming task. Arm yourself with a powerful leadership team to delegate components of the program, but stay informed and lead the charge.
As noted above, leadership is key. While searching for past articles on this topic, one theme resonated – the CEO must be visible and responsible. I have seen numerous well intended and promising program developments fail due to lack of executive visible support and responsibility. This program plan is vitally important prior to a compliance issue arising. Lead supporting departments such as compliance, information technology, finance and others through the well prepared plan of attack to tackle a compliance issue.
An initial response assessment phase in your well prepared plan should include gathering the facts. Do not jump the gun to rush a disclosure internally, publically or legally. Know your time regulatory response time frames, if applicable, and properly assess the facts not assumptions. Success in carrying out the plan hinges on gathering the facts. Whether disclosing to one individual or entity or thousands, you are best served armed with as many facts as possible. Effective communication 101 includes sharing the facts not assumptions. The more facts gathered the more confidence you will have in yourself and the compliance response plan.
Visibility was also mentioned above. Be not only visible but accessible. In order to lead the charge as noted above, you need to be accessible to the supporting departments and others involved. Even through compliance disasters, you can keep well earned respect by leading the charge not only from behind a desk, phone, or camera but also in person inside your company and outside.
During your prepare, prepare, prepare step, you should have a handy reference sheet to review all angles on the assessment, action plan, and communication plan specific to the different aspects of regulatory agencies, employees, customers, and shareholders. All may want information before your plan is executed to provide information. All may want different information given their varying interests. Successfully tackling a compliance issue involves meeting the specific needs of each affected group through the phases of your compliance response plan.
As all great leaders have ups and downs in career ventures, all great leaders learn from both the good and bad lessons. You may have identified a significant technology weakness, but your compliance response plan was well prepared and executed. Teams came together, fulfilled their responsibilities, and progress will be made to correct the technology component. After the dust settles, revisit opportunities to mitigate compliance risks such as your compliance response plan, department budgets on maintenance and updates to hardware/software, and budgets for employee education and training. Show your internal staff and external individuals or entities, if applicable, that you continue your leadership to implement improvements if needed.
Be confident in your response to compliance issues. Use the above six helpful tips to help tackle compliance issues successfully. Surround yourself with the right people to increase your likelihood of success. Delegate tasks when appropriate but visibly keep ultimate responsibility to your organization for its compliance program.
For more information on compliance issues or if you have any questions contact the Goosmann Law Firm at info@goosmannlaw.com or (712) 226-4000.