Women in Compliance

In 2007 or thereabouts, after a long and intriguing conversation with the lovely Roy Snell, I drafted an outline of an article about women in compliance – including an exploration of those traits typically attributed to women that I think make them well-suited to the position of Chief Compliance Officer.  Sadly, I never actually wrote the article!, but I have had plenty of occasions to revisit the topic over the years.

The Conference

Last week, I had the good fortune to attend Compliance Week’s Women in Compliance Summit in Atlanta.  (Sadly, due to crazy weather patterns on the Eastern seaboard, I didn’t get to attend as much of the conference as I would have liked.) A big thanks to Compliance Week for putting the conference together.  It is time for this conference. 

It was such a delight to meet up with so many women compliance professionals to connect, share and support.  There were sessions regarding how to create a good life balance; how to create meaningful connections in the field; and how to get paid what you’re worth.  (The last was led by my partner Amii Barnard-Bahn.)  And there were sessions that explored more traditional compliance topics, like the compliance officer’s role in ESG and creating compliance training that sticks. (The latter is the session on which I spoke, along with the wonderful Karen Handelsman Moore).

The key take-aways for many attendees (based on my attending a session where women were asked just that question) related to the opportunities that the conference created for networking and learning from other women.  I have always appreciated that practice sharing and supporting each other are truly core values of the compliance field – values shared by seemingly all compliance practitioners.  Those values were front and center at the Women in Compliance Summit, where networking – and learning how to connect in meaningful ways – held a significant place on the agenda.

Leadership Traits

Of course, over my many years in compliance, I’ve known a large number of amazing male and amazing female compliance officers.  And I hesitate – in 2023 – to make broad generalizations about gender characteristics.  Nonetheless, I do believe that there are qualities that we typically (stereotypically?) associate with women that are wonderful qualities in a compliance professional.  For example, consensus-building, which we desperately need in working with the business, human resources, internal audit, legal, and other parts of the organization in designing and implementing an effective compliance program. Listening skills – required  in our work with other functions, in risk assessments, in handling reports of suspected misconduct, in conducting investigations, and in every other aspect of our programs.  Empathy, which is much-needed as we help employees navigate the very complicated and highly-regulated worlds in which they operate. In addition, women’s traditional position of “other” in the halls of power can – I believe – facilitate the compliance officer’s ability to speak truth to power – perhaps the most important attribute of a compliance officer.

Developments

There have, of course, been enormous developments in gender equity more generally during the many years that I have been in the compliance field.  In the more recent past, the #MeToo movement has raised awareness of sexual harassment and assault, which has led – in at least some organizations – to changes in gender equality initiatives and corporate culture. 

There has also been a greater focus on gender diversity at the board level.  In the United States, the number of women serving on boards of directors of Fortune 500 companies increased from around 17% in 2017 to around 23% in 2022. In addition, California’s Women on Boards law (SB 826), which was passed in 2018, required all publicly held corporations whose principal executive offices are located in California to have at least one female director on their boards by the end of 2019 and either or two or three female board members (depending on the size of the board) by the end of 2021.  While a Superior Court judge in Los Angeles County struck down SB 826 as violative of California’s state constitution last year, the California Secretary of State has appealed that decision.  Regardless of the outcome of the appeal, enormous strides have been made in the number of women on boards, and diversity is an increasing area of focus in board rooms.

So, progress has most definitely been made!  There’s still plenty of work to be done (of course) to achieve greater levels of gender equality and to promote women in compliance.  Thank you to Compliance Week for officially starting that conversation in conference form. (And to women like Mary Shirley and Lisa Fine, who have been exploring this topic for some time now.)

For the past twenty-plus years, I’ve been fortunate to work with a number of wonderful compliance professionals – both men and women.  One thing that has remained consistent over that time period is the high caliber of people who are drawn to this profession – people with a desire to prevent wrongdoing, respond to concerns and help their colleagues.  It was a special opportunity to gather at the Women in Compliance Summit.  I’m curious to hear your thoughts on the value of such gatherings and any special attributes that women might bring to the profession.