Compliance and Ethics Programs and the 5 Stages of Grief​

Roy Snell, Strategic Advisory Board Member

November 11 2019

I have been watching the evolution of compliance and ethics programs for almost 20 years. It’s been interesting to see something that was virtually nowhere 20 years ago be virtually everywhere today. The implementation of compliance and ethics programs has not been without some challenges. I recently ran across the traditional 5 stages of grieving and couldn’t resist the analogy.


Denial and Isolation

Although some denial and isolation still exists, it’s much better now. In the past 20 years, many people have come to understand the benefits of a compliance and ethics program. Early adopters are now being recognized by the press, public, prosecutors, and politicians. Morgan Stanley was recently credited for effectively communicating anti-bribery laws to their employees and subsequently were not fined when an employee went rogue. Thankfully, we (most people anyway) are past the denial and isolation phase.



Some people in other professions feel that their turf is being encroached upon by compliance. This is not a turf issue, a compliance program is an additive concept. Society has asked that compliance programs supplement other professions, not detract from them. Although this issue still exists, many have moved past it.



If I had to guess where we are today in the grieving process it would have to be bargaining. An outside counsel recently wrote a piece for the Corporate Counsel blog entitled “Let’s Call a Cease-fire in the GC vs. CCO Debate.” The author is referring to compliance officer independence. He wants to bargain. This is very similar to the independence problem auditors had a few years ago, which resulted in the Sarbanes-Oxley regulation. Hopefully we won’t bargain our way into another regulation forcing independence.



This is where the analogy doesn’t really work because there really isn’t a lot of depression. Some are concerned about the cost of compliance and ethics programs. However, after seeing other companies paying fines and suffering costly PR disasters… many now see the cost benefits. Those who want to do the right thing see compliance as a positive experience rather than a depressing experience.



People in many organizations are already at acceptance. More will come. Some are deeply embracing compliance. Many have had an informal commitment to doing the right thing for years and are glad to have it formalized through the implementation of compliance and ethics programs. Some will eventually see that trust is the key to participating in the global marketplace and compliance programs can be used to attract/retain employees and business partners. It will be seen as a competitive advantage and all the grieving will be significantly reduced.

Learn More About Osprey’s Work

Osprey Compliance Software Uniting with Steele Compliance

Osprey Compliance Software Uniting with Steele Compliance

We are thrilled to announce that today Osprey Compliance Software has joined forces with Steele Compliance Solutions. Steele is one of the largest providers of compliance solutions—having pioneered innovations and investments in due diligence, third party management, compliance training and risk monitoring.

10 Business Risk Reduction Principles

10 Business Risk Reduction Principles

COMPLIANCE INSIGHTS 10 Business Risk Reduction Principles Roy Snell, Strategic Advisory Board Member June 20th 2019 Avoiding Risk of Any Kind Whatsoever May Require Some Tough Choices. So… you are looking to reduce risk in your organization or you are starting a...

Inside COI: Q&A with Roy Snell

Inside COI: Q&A with Roy Snell

ANNOUNCEMENTS & NEWS Inside COI: Q&A with Industry Leader Roy Snell Brendan Walters, Osprey Compliance Software May 29th 2019 Osprey Compliance Software is proud to bring you this inside insight interview with Roy Snell. As the ex-CEO of major compliance...

Pin It on Pinterest

Share This