A Commando Approach to Compliance: How to Listen to Compliance Feedback
By Pauline Blondet(Updated )
As humans, we do not like to be criticized, but constructive criticism is one of the best tools that we can use towards quick self-improvement. In order to continuously improve both your personal development and the enhancement of your compliance program, you are going to want to get good at listening to compliance feedback.
I'll tell you a little story about when I realized how critical having a reliable feedback loop is, especially for compliance officers given the work that we do.
The Importance of Compliance Feedback
One day, in the early times of my career, I conducted a real-life, thorough competition law risk assessment that turned out to be a fascinating exercise. From the key learnings of this assessment, I prepared a training strategy and built out tailored content very specific to our industry, to each key function in the organization. Formal training invitations were being sent out by HR to participants, so there I was, extremely excited to get started with improving our processes, lowering our risks, spreading best practices and knowledge even further, and about to host my first training sessions to sales teams.
To my surprise, 10 minutes after the official start of the session, only a couple of people had shown up. I decided to wait a bit longer. Then one person showed up, looking very unhappy, sat at the back of the room, arms crossed and bearing all the silent signals of the person who really does not want to be there.
I was very confused, why wouldn't employees be excited to gain more knowledge and practical tips on meetings with competitors? According to the inspiring Idriss Aberkane, isn’t knowledge by far the most valuable resource, the one thing that does not deplete but rather multiplies when you share it? (Idriss Aberkane, How the economy of knowledge can transform learning).
I decided to confront the employee so I walked up to him as we were still waiting for the rest of the crowd to show up asked him if he was happy to dedicate time to learning about competition law. He answered that he was here only because the training was mandatory and that otherwise he would have for sure been doing something else.
I decided to push my mini-investigation further by asking: why? He explained that, most of the time, he could not understand anything the lawyers would say, and that every time he was reaching out to the legal team he was left with more questions than answers. Whenever he attended training, he felt he was wasting his time.
That was bluntly honest and harsh feedback, which left me wondering where, as a function, we dropped the ball on caring about our end-users and internal clients.
I thanked him for his honesty and for sharing and told him that I would very much welcome his feedback about this specific training session (for more on asking for feedback when you train teams, please refer to the post I wrote on The Case for Customer Centricity). He ended up being very engaged during the session and provided me with very constructive and helpful feedback, as well as with use cases related to his specific business and operations that helped me improve my training material for future training.
Being criticized (be-it for your ideas, your projects, or your behavior) is not an easy process to go through, it even has a physical impact on you, as Adam Grant puts it in his WorkLife Podcast on How to Love Criticism:
“Physically: your shoulders tighten, your breath gets shallower. Negative feedback sets off alarm bells. It actually touches a nerve in your body.”
What is going on in your brain is even worse:
“Your mind races. You start to put up shields and mount a counterattack. If you were a peacock, you'd strut. If you were an ape, you'd beat your chest. But humans have another kind of reaction [...] our ego can get so defensive in these situations that it becomes its own little totalitarian regime. It starts to control the flow of information to our brains the way a dictator controls the media. [...] Your own ego is censoring what you hear.”
Even worse, when we hear criticism at work, we have a tendency to avoid whoever issued the critique and seek comfort and mental support from people who are of the same opinion in order to get reassurance and support.
If we never accept to actively listen to criticism it is unlikely that we will ever improve. On the other hand, if we put the right mindset to it, it can be the most transformative journey one undertakes.
Here are a few tips to get more familiar with the idea of welcoming criticism and the naysayers with a warmer heart.
1. Be Proactive About Compliance Feedback
The idea is to ask for feedback before it is given to you in an unwanted and uncontrolled manner.
The fact that you are asking prepares your brain to receive the feedback, and it also provides you with a good positioning towards the stakeholder you are exchanging with: you care about your end-users, you really want to have an impact and don’t assume you know it all.
Also, the feedback you receive is likely to be way more constructive: humans rarely like surprises, especially if your new compliance-related process or policy impacts their ways of working. By involving business teams in the definition of your program you will gain strong support from them.
2. Work on How You Receive Feedback
When you are faced with unrequested criticism or feedback, don’t let your defensive brain take over. We need challengers because they help us become better.
Breathe in, breathe out, thank the person for their honesty and ask: Can you tell me more? And truly listen to what they have to say.
As Adam Grant puts it on his WorkLife podcast:
“Every time I get feedback, I rate myself now on how well I took the feedback. That's a habit we can all develop. When someone gives you feedback, they've already evaluated you. So it helps to remind yourself that the main thing they're judging now is whether you're open or defensive. You don't always realize when you're being defensive. So call on your challenge network. Ask them to give you a second score, too. "How did I come across when you gave me feedback?" And then really listen to what they say. And respond by saying thank you.”
3. Ask for Help to Improve Your Compliance Program
When you gather or are given feedback about part of your compliance program, I also recommend that you go above and beyond by asking the person to be involved in helping you improve the point. This nurtures a constructive approach and further engages operational teams to be part of defining the compliance program.
It also builds compliance alliances and advocates throughout the organization. This concept of creating a team of “ethics ambassadors” can be massively valuable and help extend the reach and impact of the compliance team.
A Commando Approach to Compliance
I hope these ideas have convinced you to not avoid criticism, but rather to embrace it! It is no easy task, but the reward is well worth the extra effort you will put in.
In case you didn’t catch the introductory post, Key Compliance Challenges from the Field: Meet GAN’s Newest Expert, A Commando Approach to Compliance is all about the very concrete challenges compliance officers face in their day-to-day lives. The commando aspect of this title refers to the diligent and proactive approach that I believe drives the best results for compliance leaders. This blog series aims to address some of the most common but least addressed hurdles that compliance professionals strive to overcome. Sign up for our newsletter to ensure you are up to date on the latest commando blog posts!
DOJ issues further guidance, warnings on ephemeral messaging apps
Federal appeals court upholds 5.6B USD Visa and Mastercard settlement
What is compliance risk management?