Moving to the Chief Compliance Officer (CCO) chair can be quite a daunting challenge. The first time you do so can bring feelings of fear leading to terror. However, everyone who has moved up to a leadership position in any organization has felt some of these some emotions. I was therefore intrigued by a Harvard Business Review (HBR) article by Rebecca Zucker, entitled, “How to Succeed When You Have Big Shoes to Fill”, on dealing with these emotions and the tactics you can use to succeed in a new position. Having a great opportunity also presents big challenges. Zucker provided some strategies that you can utilize to demonstrate to yourself and others that the you are the right person for any big job.
Do your homework before you start. Hopefully you studied your new role during the interview process before you accepted the position but no matter how much you did; you need to ramp up that study and learning before your first day in the new position. This may involve getting up to speed on the company’s product, key clients, industries, or area knowledge adjacent to your area of compliance expertise. Zucker writes, “If you have time off before you start your new role, it’s good to take some time to unwind from your previous job, but make sure you also take time to ramp up for your new one.”
Be yourself. I think this may be the hardest for someone when they initially go into senior management or go to a new organization. Do not try to be someone you are not; i.e. your predecessor. Zucker said, “Being unapologetically authentic will earn you respect and help preempt judgment from others who are likely to compare you to your predecessor.” She cited to “Christine Lagarde, former head of the International Monetary Fund, took over in November 2019 as president of the European Central Bank. Upon starting her new role, she declared, “Each and every president has his or her own style of communicating. So, I know some of you are keen to compare and rate or rank. I will have my own style. So, as I said before: Don’t overinterpret, don’t second-guess, don’t cross-reference. I’m going to be myself, and therefore probably different.””
Understand and manage stakeholder relationships. Obviously, this is a key element for CCO success. You must have the ability to establish and effectively manage stakeholder relationships, both internal and external. This can include the Board of Directors, the Chief Executive Officer (CEO) and senior management, sales teams, key third parties and your compliance customers. Zucker suggests asking questions such as “In your view, what should my top three priorities be over the next six to 12 months, and what would success look like to you? What other internal and external relationships are most important to support these priorities? What concerns do you have, and how can I address them?” It is key to build these relationships as soon as possible.
Assess the team. Do you have the right compliance team in place? Are you coming in after or even during a compliance crisis? If there are gaps, you will need to address them as well as performance issues on your team. You need to make sure your compliance team can handle the tactical issues while you work on the larger strategic priorities of compliance. In many ways a CCO is only as good as their team. It may well be that the former CCO was not comfortable with having the requisite difficult conversations with compliance department employees about their job performance. You need to make some early assessments and if your team does not meet your needs you need to take action. Zucker noted, “Given your top priorities, you’ll want to assess if you have the right team to accomplish them.”
Check your mindset. Having big shoes to fill can lead to lots of emotions and even conditions. Zucker noted one of which is the Imposter Syndrome “especially as you get more senior and are faced with completely new challenges. Even if there is evidence to the contrary, you may feel like a fraud or question whether you can measure up to the standard set before you. This is normal to some extent and even has some benefits, but it’s something to manage as you get your bearings.” Believe me, you would not have gotten the job if you were not capable.
Seek ongoing feedback and support. Having a set of trusted advisors is always important but here you need to be open, honest and have frequent conversations with the key stakeholders in your organization. Zucker advises that you should “Create feedback loops with your key stakeholders for them to share early and often what’s going well and what’s going less well, so you can make real-time adjustments, as needed.” She cautions, however, “not everyone is going to like what you do. With your team, recognize that giving upward feedback often feels very risky, so you will need to give your team explicit permission to do so. Your job is to then listen — if you don’t, rest assured that your reports will not likely try a second time, and you will not get the information you need to hear.”
Not enough can be said about the CCO’s need to listen and that is the final addition I would make to Zucker’s list. Get out of the Ivory Tower, hit the road and listen. Let the employees see you and hear you. But listen to their concerns. If you can address quickly and efficiently do so. Peter Parker’s Uncle Ben said that with great powers comes great responsibilities. I would adapt for the CCO to “with great opportunities comes great responsibilities”. As a first time CCO you will have great opportunities. Embrace the responsibility that comes with such opportunity and you will go a long way towards success.
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