For people who don’t know, what does Deluxe do?
Most people that know Deluxe know us as a check company. Over 100 years ago, our founder literally invented the checkbook. Since then, we have grown to help enterprises, small business and financial institutions deepen customer relationships through trusted, technology-enabled solutions.
What is most surprising about being a CCO, something you didn’t think would be as big a deal as it is, or something you spend more or less time than you thought you would?
I didn’t expect to spend as much time on administrative tasks as the job requires. In my head, there would be infinite time to implement my grand compliance vision, but in reality, I answer hundreds of emails a day and move a lot of paper. I still have my vision, but it turns out I’m bound by the realities of time.
You are an attorney and worked in several roles providing compliance support services--what prompted you now to become a compliance officer?
If you add it all up, I’ve been a licensed attorney for 10 years, and spent the last six in the compliance arena. I have a strange career path that includes four years at the Society of Corporate Compliance & Ethics, and the Health Care Compliance Association. While at SCCE, I was able to feed my interest and passion in compliance in a new way. I met so many amazing compliance professionals, and was inspired by what they were doing and interested in getting that hands-on experience myself.
I joined Deluxe in September 2017 as a senior member of the compliance team. In that role, I was able to grow my skills as a compliance professional and got the opportunity to manage others on the team. From the moment I started at Deluxe, my goal was to be a chief compliance officer; I just didn’t know where or how long it would take. As it turns out, the opportunity presented itself a bit sooner than I expected--and right where I was.
When you come into a company in a new role such as yours, how much do you keep in place to ensure continuity, while still making changes and putting your own imprint on the program? How do you strike that balance?
One of the main challenges the compliance function faces is getting buy-in from the business. Now imagine trying to get buy-in when there is turnover and program changes; it can be very difficult. Like every program, we have some pieces that are perfect and others that could use some attention. I have built my vision on keeping what works and fixing or stopping what doesn’t.
In every change I implement, I try to make it clear to my boss, my team, and my business partners what I’m doing and why I am doing it now. Change can be scary, but I find that providing as much context and transparency as possible is the way to counteract that fear. Give people the why and let them make the right choice.
What is your plan to better embed ethics and compliance throughout the company?
The ultimate goal is for compliance to become trusted advisors and have compliance permeate throughout everything we do. It starts with conversations and asking how compliance can help. We have to earn trust from the business, not demand it.
We have to be agile and approachable and friendly. We have to give the right advice at the right time. We have to explain why we’re doing what we’re doing – and how it will lead to fewer risks and better business results.
On a less philosophical level, we are performing enterprise-wide risk assessments and strengthening our core programs that address those risks. From there, my goal for 2019 is to kick off a compliance ambassador program for the entire Deluxe enterprise.
I believe that having a point person in every location will bring compliance to life and give each employee the opportunity to have face-to-face conversations with representatives of the compliance function. One cannot underestimate the power of human interaction. That’s the same reason I bribe people with a pantry full of snacks in my office.
What does ethics and compliance need to do to better articulate to the other parts of the business that companies that behave better perform better than those that don’t?
I try to see compliance through the lens of carrots, not sticks--highlight the positive aspects of maintaining compliance, speak to the power of good choices, incentivize employees for acting ethically, etc. So my worldview is really aligned with what the data show.
At Deluxe, we have thousands of employees working on hundreds of different products and services. The vast majority of those employees want to do the right thing. That’s the easy part. The hard part starts when it comes to the business having to make choices to maintain compliance, but those choices will no doubt cost us money, or keep us from making it.
Deluxe is not unique here; any company that sells anything struggles with this, but the numbers speak for themselves. If my overly optimistic appeal to every employee’s better angels fails, I can always just break out the math.
What can E&C do to gain more influence and attention from the board?
When it comes to the business, I’m a strong believer in earning their trust. When it comes to the board, I am more of a demand-to-be-heard kind of girl. By definition, boards of directors should be sophisticated business professionals; this isn’t the audience I tiptoe around.
My board strategy is to provide the information they need in the clearest manner possible and in a way that instills confidence in me as a compliance leader, but also demonstrates my deep understanding of the business. Once compliance can be seen as keen business advisors, rather than the department of “no,” we’ll get the boards on our side.
(NOTE: There will be no newsletter July 3 because of the holiday. The next newsletter will be published July 10.)