Mike Volkov wrote a great article on what qualities make for a good Chief Compliance Officer (CCO). I recommend reading the entire article, but what’s at the heart of Volkov’s observations is that it boils down to listening. Great CCOs don’t hole up in their offices with data – they get out to the far reaches of the company and listen and interact with employees. Volkov points out that listening allows CCOs to better understand the situations that employees face. Listening also helps bolster the view of the Compliance and Ethics department (C&E) as a resource to help employees rather than that of C&E as the company’s police force. I agree with this and would add that listening offers another benefit, more subtle but with the potential for lasting impact.
I have a friend who lives in Singapore, and Diane and I have been discussing code switching recently. Code switching is defined as mixing languages or speech patterns in conversation. You can hear it most obviously in multilingual households (my sister and I frequently code switch when speaking with our parents, for whom English is not their first language). It is often a signifier of belonging to a particular group. Because of this, we also hear it when someone outside a group uses the slang and speech patterns of the group to try to fit in or find common ground. A Spanish language commercial for Nescafe Clasico has parents using “OMG” and “LOL” in a conversation with their teen daughter. My friend reverts to her Virginia drawl when she meets with clients south of the Mason-Dixon line.
My last post was on the need to shorten our C&E communications to employees by a lot. I commented on the lawyer’s tendency to be exhaustive and detailed in the reasons for being compliant and ethical. What I didn’t highlight last week was that the content of C&E’s communications, even when short, need to bear more resemblance to the day-to-day work of our employees if our messages are to be absorbed. Communications should be in the employees’ voice, not C&E’s. In other words, C&E needs to engage in more code switching.
Effective code switching isn’t easy, though. In the Nescafe commercial, the parents using teen slang is done in a way meant to make the viewer cringe. The parents are using the slang correctly but not genuinely. Instead of underscoring the things they have in common, it widens the generation gap and inspires an eyeroll in the teen. I’ve had the privilege of discussing strategic management issues with over a thousand legal, C&E, finance, and HR executives in North America, Asia, Europe, Australia, and Africa. My sense is that in order for code switching to be effective, it has to be organic and genuine and not solely for the purpose of shortcutting the process of building relationships for the purpose of persuasion. We know when someone is faking. We may tolerate it silently, or we may out of politeness pretend that it’s not happening. We definitely won’t trust or rely on someone we know is faking, though, and that’s why the code switching has to be authentic.
C&E communications need to be written and created in a way that incorporates our employees’ perspective and vernacular. Code switching offers us a method of demonstrating common identity and concern. Code switching is most effective when it’s authentic. CCOs and C&E executives who take the time to meet with employees and listen to them are more likely to be able to incorporate code switching organically and with the right, perceived intent. The benefit of this is C&E communications that are easier to absorb but also are more likely to inspire the desire to absorb. Our employees have always had the ability to read what we send them. Wouldn’t it be great if they wanted to?