Compliance Lessons from Venice: How the Venetian Gondolier Informs Your Compliance Program

If there is one thing that is ubiquitous throughout this city it is the Gondolier, the Venetian Gondola boatman. You are never far from hearing their cry of “Gondola, Gondola” to attract tourists for a fabled and romantic gondola ride. One thing I notice about the Gondolierthat in addition to having a stout pairs of lungs, they are almost all in very good physical condition. They have to be piloting this very old craft by hand in and around the crowded waters of Venice.

I thought about this as a metaphor for improving your compliance program. As a CCO or compliance practitioner, the more you can get out of the office, into the field and meet the troops the more fit your compliance program will be. Any best practices compliance program should have input from the geographies, cultures, business units and corporate functions within the company. It is well understood that a compliance procedure that works well in the US may not work in Indonesia.

Compliance is about people and that means it is about relationships. But perhaps more importantly, is the development of personal relationships. If you meet with your international sales team, my corporate experience is that they will appreciate that you took the effort to travel to train them or meet with them. They are also more likely to tell you things in persons than they would via email or over the phone. One of the criticisms of anonymous hotlines and other internal reporting mechanisms is this lack of the personal experience that can lead to mis-trust if not distrust. Getting out into the field and meeting folks can go a long way to overcome this frailty of human nature.

Finally, by getting out of the office and working directly with other company personnel, you can set expectations appropriately. This is true for the compliance practitioner whether you are dealing with third party vendors in the Supply Chain, agents and other foreign business representatives, your employee base, senior management or the Board of Directors. You must set the expectation that if something occurs that materially impacts these expectations. By properly managing the expectations of the company’s compliance group with the relationships that you have established in the company, you will make the doing of compliance less stressful for all involved.

My observation that Gondolierstend to be physically fit ties directly to the job they have to do, propelling a gondola. Yet as a CCO or compliance practitioner you can get out of the office and make your compliance program more robust and get it in better shape.