THE ART & SCIENCE OF
[INFLUENCE & PERSUASION ] THE ART & SCIENCE OF by Kristy Grant-Hart & Keith Read
TOOLKIT FOR THE MODERN COMPLIANCE PROFESSIONAL
HOW DO YOU INFLUENCE DECISION-MAKING?
It was a huge step in the industry for a compliance professional to be named a member of the C-Suite. Now the next challenge is how to be e ective. Some 58 percent of chief compliance o cers state they are not su ciently integrated into corporate strategy, according to recent results from a survey conducted by Consero as part of the Global Corporate Compliance & Ethics Data Survey. Couple that figure with Consero's statistics around sta ng -- over 20 percent say they experience insu cient sta ng, and it's plain as day the opportunity that exists for compliance o cers to exert influence across the organization.
But yet, the how remains elusive, under-reported, under-discussed and under-researched. That is, until now.
The Compliance Influence & Persuasion Toolkit is that how. Penned by Kristy Grant-Hart, author of How to be Wildly E ective Compliance O cer (Brentham House, 2016) and Keith Read, Convercent's Director, Europe, the guide is equipped with the tools you need to succeed in today's compliance industry -- and sustain lasting influence across your business for years to come.
Without further ado, let's jump right in.
2
INFLUENCE
TABLE OF CONTENTS
PART TWO:
In Theory: Persuasion and Influence w/ Keith Read
p.18 p.19 p.20 p.21 p.22 p.23
Introduction Reciprocity Liking Commitment & Consistency Scarcity Authority & Social Proof
PART ONE:
Actionable Insights to Make a Sound Compliance Decision w/ Kristy Grant-Hart
p.6 Getting It Right p.7 Dealing With Di cult Decisions p.8 Compliance O cer Decision Tree p.10 Is It Legal? p.11 Is It Ethical? p.12 Is It Against Policy? p.13 Is It A Bad Idea? p.14 Compliance Dashboard
3
PART ONE
Actionable Insights to Make a Sound Compliance Decision Kristy Grant-Hart
4
ABOUT YOUR GUIDE
KRISTY GRANT-HART
Kristy Grant-Hart is the author of How to be a Wildly E ective Compliance O cer. She is Managing Director of Spark Compliance Consulting and is an adjunct professor at Widener University, Delaware School of Law teaching Global Compliance and Ethics. She's been featured in the Wall Street Journal, Financial Times, Compliance Week, and on the cover of Compliance and Ethics Professional Magazine. Before launching Spark Compliance, Ms. Grant-Hart was the Chief Compliance O cer at United International Pictures, the joint distribution company for Paramount Pictures and Universal Pictures in 65+ countries.
Kristy is an American living in London with her British husband Jonathan and her two Californian rescue dogs, Samuel and Mr. Fox.
She can be found at: or KristyGH@.
5
GETTING IT RIGHT
Every day, all day long, compliance o cers are asked the question, "Am I allowed to do this?" Sometimes the request is straightforward and easy to answer, but other times the question represents a trap. Knowing how to navigate the sticky variations of the business' requests can be the di erence between being a wildly e ective compliance o cer and one who is out of a job. Worse, if you get the answer wrong in a critical context, you could end up the company's scapegoat who might be in the crosshairs of a prosecution.
Compliance o cers instinctively know when there is a question they shouldn't answer. But pressure from the business and a desire to please often cloud the compliance o cer's judgment about when to o er advice versus when to make a definitive decision about the outcome of a problem.
6
DEALING WITH DIFFICULT DECISIONS
Di erent business people pose di erent risks to the compliance o cer. Many employees have nothing but good intentions when they come to the compliance department. These people come wanting advice and counsel. Others have a more nefarious purpose. Sometimes managers or executives are in a tough spot ? they have to make a decision they know is unpopular or unwise, and they want someone to blame it on. Using the phrase, "Compliance told me I could!" may alleviate some of this discomfort and place the blame away from them if the decision goes badly.
Other employees or managers will use the Compliance Department as a crutch, running every little decision by the department, even when the issue is unrelated to topic areas the compliance departments manages. These employees also want to eliminate the possibility they could be wrong. "Compliance said it was OK" is their mantra, even when the decision isn't for compliance to make.
With all these di erent people to manage, how can a compliance o cer know when to give advice and when to make final decisions?
The answer is to use the Compliance O cer Decision Tree.
7
COMPLIANCE OFFICER DECISION TREE
QUESTION 1 NO
Is it legal?
YES
STOP HERE. If business wants to move forward anyway, go to the Board, ask legal counsel to comment, and/or do everything you
can to intervene.
QUESTION 3
Is it against our Policies?
YES NO
Compliance O cer writes new policy
OR
Compliance O cer documents exception
Compliance O cer ensures followthrough happens
according to policy
QUESTION 2
NO
Is it ethical?
YES
QUESTION 4
Is it a Bad Idea?
Evaluate and report on risk
Business makes decision to go forward or not
If it does not go forward, consider whether to document
the decision
If it goes forward
Compliance O cer documents risks and
puts policies and procedures in place
8
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