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The Compliance Professional's Credo

This is a list of things I commit to as a compliance professional. It’s not an exact science, an exhaustive list, or a standard―it’s just my perspective. Use this credo as a starting point for your own compliance credo.

  • I prevent, find, and fix ethical and regulatory problems and strengthen my organization’s ethical culture using all elements of a compliance program.

  • I am concerned about all risk areas and laws.

  • I base my compliance program on Chapter 8 of the Federal Sentencing Guidelines.

  • I regularly reread the Code of Professional Ethics for Compliance and Ethics Professionals to reset my focus.

  • I am conflict-free, unbiased, and impartial.

  • I seek support from my peers and I seek to support my peers

  • Interpersonal skills such as collaboration, negotiation, and influence are keys to my success. I fully commit to having a strong emotional IQ.

  • I help departments minimize the impact of compliance on business effectiveness.

  • I help leadership effusively communicate their commitment to compliance and ethics.

  • I regularly ask people throughout the company if they are aware of any problems. I don’t just rely on the hotline. I make it easy for people to report issues.

  • I regularly conduct compliance education sessions and then follow up with a few private interviews asking if employees are aware of any problems identified in the training.

  • I protect those who report issues and facilitate trusted anonymous reporting.

  • I use facts and the truth, and effect due process to protect those who are falsely accused.

  • I will work with the organization’s leadership to address known issues. I gather facts and tell leadership the truth. I’m not influenced by internal politics. I protect leadership from bad advisors and seek to keep all employees out of trouble. I report all material impediments to the implementation of an effective compliance program to leadership.

  • I will report to a subcommittee of the board on a quarterly basis, the whole board annually, and regularly provide education to the board.

  • I avoid finger-pointing and lecturing. I will recommend discipline when warranted.

  • I consider risks created by partners, advisors, contractors, and third-party companies.

  • I work with in-house and outside counsel―I don’t work for them.

  • I am aware that conflicts of interest create problems and can be the enemy of resolving problems. I seek to remove or effectively manage conflicts of interest when possible.

  • I believe I need a seat at the table to prevent problems before they start.

  • I will not participate in misconduct. Integrity is my core principle and I will not compromise it, even to right a wrong.

  • I wait until a comprehensive investigation is completed before discussing specific details or recommendations, but will keep leadership generally aware of my progress.

  • I only discuss possible ethical and regulatory issues with those who need to be involved.

  • I am willing to delegate any compliance activity, but will assure it gets done correctly.

  • I help everyone in the company take on some responsibility for compliance.

  • I use outside specialists, not generalists, for high-risk activities.

  • I cannot be responsible for both operations and compliance for the same area.

  • If I discover an unrelated problem during an investigation, I will investigate it thoroughly.

  • I do not let the pain from fixing a problem deter me and I will resolve it internally.

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