The Integrity Gap

Compliance booted to the back office?

Is it time to take compliance "out into the snow and put a bullet in the back of its head? " That lovely phrase was beloved of a former boss, who'd use it for any idea or strategy that hadn't worked.

The Integrity GapCompliance booted to the back office?

Is it time to take compliance “out into the snow and put a bullet in the back of its head?” That lovely phrase was beloved of a former boss, who’d use it for any idea or strategy that hadn’t worked.

There are tensions that we struggle to talk about in public, but EVERYONE I speak to privately acknowledges:

😬 The list of things to comply with is too long 😬 This (can) make compliance performative 😬 Which then erodes trust, as people see through that

If this continues, compliance will cease to be what (many) hope and think it should be - a strategic part of decision-making and critical input into an organisation’s values and purpose.

The solution, I feel, is to get on the front foot. Decide what issues matter to you as an organisation. The UN’s Sustainable Development Goals (below) indicate they were arrived at by a committee (17?). But that doesn’t mean they’re not helpful; they’re not helpful all at once.

The 17 SDGs can be parsed further, and I’d suggest you do that. For instance, it might make sense for a clothing retailer to focus on those around water (it takes 12,000+ litres to make one cotton t-shirt), worker welfare (fair wages, gender equality), and carbon footprint (2-8% of greenhouse gas emissions stem from the fashion industry [10], with sectoral C02 emissions forecast to rise 50% by 2030 [11]). It makes less sense they focus on sanctions, and other issues (GDPR to fraud) will be niched down to those finite areas that could be impacted.

  1. UN Alliance aims to put fashion on path to sustainability, published 12 July 2018.

  2. Sadowski, Perkins, and McGarvey, 2021. World Resource Institute and Apparel Impact Institute, Roadmap to net zero; delivering science-based targets in the apparel sector.

But how, then, should we comply with all the other acronyms, which could expand forever? E, S, G, R(eputational), P(olitical), S(security), HSE, GDPR, FCPA, etc.

Triage, then comply. Triage requires filtering issues by impact and influence, which makes compliance rightsized (not overwhelming). It’s not quite that simple, but it can be made a lot less complex than you might first realise… happy to chat if you’re struggling.

If we’re to save compliance from the snow execution, we need to make risk, sustainability, and ethics more than mere performative box-ticking compliance, we must rightsize and prioritise.

Careless chatbots cost

From Tortoise Media

“A lesson for companies preparing to roll-out ever more sophisticated chatbots to improve customer service: if they get it wrong, it’s on you. A Canadian tribunal has ruled that Air Canada has to pay up after its chatbot gave the wrong information to a customer booking a flight after his grandmother died in Ontario. The airline offers a bereavement discount if the request is submitted before a last-minute flight; the chatbot told British Columbia resident Jake Moffatt that he had 90 days to apply, according to the Washington Post.

Air Canada reportedly argued that the chatbot was a separate legal entity that was “responsible for its own actions”. Not so, said the tribunal: it should be “obvious” that Air Canada is responsible for all the information on its website, including the chatbot. Air Canada was ordered to pay just over $600 in damages and tribunal fees; it says it will comply with the decision.“

More Ethics Insight writing

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