
Caught
What started as ‘just a little extra cash’ turned into lies, cheating, and broken laws. I told myself nobody was hurt, nobody would ever know—but compliance knew. Now I’m facing

By Joe Murphy, CCEP
Who would have thought one could develop a major book on the topic of compliance liaisons or coordinators? From the time I was working inhouse I believed compliance and ethics programs had to have reach and presence outside of headquarters and throughout the business. I wrote about this early on, in 1996, Joseph E. Murphy, “Facility Compliance Coordinator Position Could Help Ensure that Compliance Program Reaches the Field,” Prevention of Corporate Liability 12 (Dec.16, 1996). Since that time there has been quite a bit written on this topic; in Ideas & Answers we have published an entire bibliography on this aspect of compliance: see Field & Business Unit Compliance & Ethics Managers.
Then along came Matt Silverman’s amazing book on these champions, The Champions Network (Ignite Press; 2023). Matt has approached this in a depth that is startling. He begins with research dealing with crops in the Midwest, and what moved farmers to adopt new techniques. He then brings this over to the far-reaching subject of what will move people in organizations to change their views and approaches. From this he leads to a systematic approach to creating champions networks including ones that can promote compliance and ethics throughout a company or other organization.
Of course, in our field we pay attention to what the government will consider effective, so there is also reference to a change in the Department of Justice Criminal Division’s guidance on compliance program that now recognizes “champions.” U.S. Department of Justice Criminal Division, Evaluation of Corporate Compliance Programs (Updated March 2023) . In reality, when anyone assesses your compliance program they should be attuned to what the employees say about the company. If the program only exists in the imaginations of the legal department then no government anywhere should give the program credit. But if, wherever you go in the company, the program has a presence and is visible, then the program is a real factor.
How do you get your program to have presence throughout the company? How do you impress your employees in even remote parts of the company, or even in the different departments in headquarters? That is the brilliance of the champions, liaisons, coordinators, or other compliance representatives throughout the company. If the champions network is well designed and well staffed, as outlined in Matt’s book, it can be a key step in achieving this objective.
In my writing and speaking I am known as a strong advocate of making incentives a central part of any compliance program. In his book Matt picks this up and heartily endorses applying this approach to the champions network. On page 75 he provides a succinct and practical list of steps that can easily be taken as incentives and recognition for the compliance champions. These include steps such as having a “Most Valuable Champion” award, providing substantive reviews of the champion’s performance, or awarding a salary increase or bonus.
Whether you are just starting out in compliance and ethics, or have been doing this for over 40 years, by all means read this book. If we are to be successful in bringing compliance programs to life, ensuring there is a supportive culture, and reaching all parts of the business, The Champions Network is the guide we need.
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