Across industries and companies, the CCO role is one of incredible importance — and incredible diversity. Here, we provide a broad toolkit for emerging directors, AGCs, and senior level compliance professionals to use to chart their own course and build skills to become a CCO.
THE E&C PROGRAM IS AN ECOSYSTEM
CCOs are systems thinkers, looking across a vast landscape of risk, understanding how each element of the program works in harmony, and seeing the “forest” of initiatives that advance ethics and compliance. CCOs are strategic thinkers, often not mired only in day-to-day decision-making, who ruthlessly prioritize their time and attention. CCOs understand people and what drives them to succeed, allowing a unique perspective on building pathways that invite employees to make a responsible decision in the face of performance pressure, time constraints and working beyond capacity.
Ethics & Compliance Culture: Building Employee Capabilities. Developing responsible employee decision-making and positively impacting employee behavior.
Creating Infrastructure & Systems to Support Employees. Knowledge of—and leadership for—systems and controls that support employee decision making and manage risk.
What’s Ahead and What’s Working: Detection and Monitoring. Programs reassuring leadership that compliance culture and systems are operating as expected and find areas for continuous improvement.
Speaking with Impact: Reporting. Tailoring a message to your audience using qualitative and quantitative data with a compelling narrative to report on program effectiveness and needed improvements.
UNDERSTANDING AND LEADING THROUGH RISK
CCOs understand how the business drives risk, and they have a pulse on the company’s risk appetite. They look beyond the risks they know to those they know less. Become conversant in the company’s highest risks and work toward leading others who manage them day to day.
How We Build Things: Research and Product Design Risks. Examples include privacy, University partnerships, theft of trade secrets, insider trading, human rights, biased technologies, accessibility, consumer safety.
How We Make Money: GTM Risks. Examples include channel stuffing, revenue manipulation, roundtrip transactions, fraud, kickbacks.
How We Partner: Third Party Risks. Examples include competition, privacy, side agreements, conflict minerals, modern slavery.
Where We Operate: Geo Risks. Examples include sanctions, trade, export controls, state privacy or healthcare regulations, permitting and licensing, building or plant construction, data localization, social media platform content regulations.
Who Our Customers Are: Public, Private, Non-Profit Risks. Examples include public procurement, government contracting, bribery and corruption, World Bank or similar development bank funding, sanctions.
Our “For Good” in the World: ESG. Examples include materiality assessments, programs supporting human rights, sustainability, and Diversity, Equity, Inclusion, and Belonging (DEIB).
CCOs cultivate a reputation as a business partner, curious problem-solver and influencer—both within a company and beyond. CCOs spend time building relationships, trust and credibility through active listening, demonstrating thought leadership and expertise, and selflessly working to build others up.
Looking Around and Up: Expanding Relationships with Company Peers and Leaders. Build allyship beyond your core stakeholders while nurturing your E&C and Risk Management relationships; enable a company-wide community. Examples include roundtables, summit sponsorships, offering to partner on pilot projects, loaning your resources toward a shared initiative, job-sharing, being available as a sounding board.
Looking Outside: Expanding Your E&C Network and Developing a “Brand” as a Thought-Leader. CCOs are vision-setters, not just internally but also sought out as experts externally. Build momentum in the E&C and regulatory community through your ideas, learn-it-all attitude, offers for benchmarking, speaking, teaching, and inter-company collaborations.
FROM MANAGEMENT TO LEADERSHIP
Defining the Org: Vision, Mission, Programs, Goals, Projects. People need purpose. CCOs step back and reflect on their team’s collective contribution to the company mission—and articulate this in a clear and compelling way that includes an evergreen purpose and how today’s programs contribute.
Empowerment + Accountability: Moving Away from D2D Work into Strategy. While sometimes comfortable, micromanagement is antithetical to a CCOs role. CCOs lead through conscious empowerment, giving teams freedom to fail or succeed and demonstrating an “I have your back” attitude that shows up in meetings and projects.
Seeing the Future: Shifting Focus to a Longer-Term Horizon. CCOs look far ahead towards success factors that are transformative for the business, not just the compliance program. Spring-boarding off the empowerment given to their teams, CCOs “see the future” alongside their executive team peers and chart a course for how E&C will support and enable company growth.
Know Your People. This involves building team cohesion, identifying high potential employees, succession planning, and managing headcount.
GROWING AND MANAGING A BUSINESS
CCOs model the best corporate behaviors around effective and efficient use of corporate assets. Developing rigor in your own org is a pathway to growing capabilities to appreciate that Compliance is a business unit.
Spending Wisely: Budgeting and the Compliance “P&L”: CCOs recognize the need to engage early with leadership and those involved in the budget process to lay the groundwork for resource requests. Be prepared to tie each line in a budget request to a specific risk, a specific company objective or technology that will reduce the need for further headcount. With data at their fingertips, CCOs demonstrate the efficiencies achieved through the adoption of technology and the sunsetting of legacy programs in favor of more impactful initiatives, and the savings achieved from investigations, monitoring and reviews of other programs.
Bringing Others Along: Prioritize change management, business reviews, and informing your team.