I have worked with more than 175 firms in general insurance, providing compliance assistance.
Iโve found that the best leaders consistently possess certain fundamental qualities & skills when viewed through a compliance lens.
๐๐ผ๐ ๐ฑ๐ผ ๐๐ผ๐ ๐ฐ๐ผ๐บ๐ฝ๐ฎ๐ฟ๐ฒ ๐ฎ๐ด๐ฎ๐ถ๐ป๐๐ ๐๐ต๐ฒ๐๐ฒ ๐ญ๐ฌ ๐ฐ๐ผ๐บ๐ฝ๐น๐ถ๐ฎ๐ป๐ฐ๐ฒ ๐น๐ฒ๐ฎ๐ฑ๐ฒ๐ฟ๐๐ต๐ถ๐ฝ ๐ฎ๐๐๐ฟ๐ถ๐ฏ๐๐๐ฒ๐?
1. ๐ฟ๐ค๐ฃโ๐ฉ ๐๐๐๐๐ง ๐๐๐๐ค๐ช๐ฃ๐ฉ๐๐๐๐ก๐๐ฉ๐ฎ
Good leaders don’t say ‘compliance is someone elses job’. They own responsibility for compliance in their business area & are accountable & take ownership for control-breakdowns, issues & breaches & resultant customer remediation.
2. ๐๐ง๐ค๐ฉ๐๐๐ฉ ๐ฎ๐ค๐ช๐ง ๐ฉ๐๐๐ข ๐ข๐๐ข๐๐๐ง๐จ
They protect the careers of their team members. They ensure that compliance arrangements provide a safe environment for team members to perform their work. Good leaders make staff aware of their compliance obligations through training &, consistently, through team meetings.
Good leaders protect team members from the team members ‘compliance ignorance’ through adopting Sandard operating procedures, implementing sales, underwriting & claims guidelines & through business documented business practices, systems & ongoing training.
3. ๐พ๐ง๐๐๐ฉ๐ ๐ ๐จ๐๐๐ ๐๐ฃ๐ซ๐๐ง๐ค๐ฃ๐ข๐๐ฃ๐ฉ
Leaders create a safe environment for team members to self-report incidents, breaches & complaints quickly. They accept that team members are human & make mistakes. They are fair & equitable in their responses to compliance incidents.
They remain calm & focused on facts when presented with potential customer or business harm arising from something going wrong within their team. They remain focused on remediation & rectification and not retribution.
4. ๐ฝ๐ ๐๐ฃ๐๐ค๐ง๐ข๐๐ ๐๐ฃ๐ ๐๐ฌ๐๐ง๐ ๐ค๐ ๐๐ฃ๐๐ช๐จ๐ฉ๐ง๐ฎ ๐๐ค๐ข๐ฅ๐ก๐๐๐ฃ๐๐ ๐๐๐ฅ๐ฅ๐๐ฃ๐๐ฃ๐๐จ
Leaders stay on top of compliance change, they are curious & seek to understand how upcoming changes (such as CPS 230, FAR, Code review, flood inquiry) may impact their area of accountability & risk profile.
They seek out the advice & counsel from compliance & legal specialists to fully understand the impacts of regulatory (& Code) change.
They openly discuss with their team news headlines (commission payments, premium affordability & availablity) even when those conversations may be difficult due to potential business impacts.
5. ๐๐๐ฉ๐๐๐ฃ ๐๐๐ฉ๐ ๐๐ค๐ง ๐ฎ๐ค๐ช๐ง ๐๐ง๐๐ ๐ค๐ ๐ง๐๐จ๐ฅ๐ค๐ฃ๐จ๐๐๐๐ก๐๐ฉ๐ฎ
They obtain data (incidents, breaches, complaints, control testing, QA etc) to inform them of the adequacy of compliance arrangements for their area of accountability. They drill-down & ask questions including when there is a lack of data
They compare their area’s data with other business areas from a learning perspective not from a competition perspective.
6. ๐๐๐ก๐ ๐ฉ๐๐ ๐ฉ๐๐ก๐ – ๐๐ฉ๐ฉ๐๐ฃ๐ ๐๐ฃ๐ ๐๐ข๐๐ง๐๐๐ ๐ฎ๐ค๐ช๐ง ๐ค๐ฌ๐ฃ ๐ฉ๐ง๐๐๐ฃ๐๐ฃ๐
They are mindful of the compliance shadow they cast.
Good leaders enthusiastically inform team members about upcoming compliance training the leader is attending & share the outcomes & learnings back with the team. They consistently demonstrate through their actions how compliance protects the business, their team members, customers & business partners
7. ๐๐จ๐ ๐๐ค๐ข๐ฅ๐ก๐๐๐ฃ๐๐ ๐๐จ๐จ๐ช๐๐จ, ๐๐ง๐๐๐๐๐๐จ ๐๐ฃ๐ ๐๐ค๐ข๐ฅ๐ก๐๐๐ฃ๐ฉ๐จ ๐๐จ ๐ ๐ก๐๐๐ง๐ฃ๐๐ฃ๐ ๐๐ญ๐ฅ๐๐ง๐๐๐ฃ๐๐
They use data from their own area together with other business areas to provide learnings & business continuous improvement. They use story-telling from their lived experience to bring compliance to life for the team. They use practical business examples to create lightbulb moments for their team.
8. ๐๐ฃ๐จ๐ช๐ง๐ ๐๐ค๐ข๐ฅ๐ก๐๐๐ฃ๐๐ ๐๐จ ๐ฅ๐๐ง๐ฉ ๐ค๐ ๐๐ค๐ฃ๐จ๐๐ฆ๐ช๐๐ฃ๐๐ ๐ข๐๐ฃ๐๐๐๐ข๐๐ฃ๐ฉ
They know the difference between a team member making a mistake & performance management. They are fair & equitable when dealing with poor compliance performance.
Consequence management is transparent & viewed by team members as fair & equitable.
9. ๐๐ช๐ฅ๐ฅ๐ค๐ง๐ฉ ๐ฉ๐๐ ๐๐ช๐จ๐๐ฃ๐๐จ๐จ โ๐๐ค๐ข๐ฅ๐ก๐๐๐ฃ๐๐ ๐ฉ๐๐๐ขโ
Good leaders are advocates for the business compliance team. They can articulate business (1st line) & compliance (2nd line) responsibilities. They welcome the compliance team to their team’s meetings & provide training to theย compliance team about their teams business operations.
10. ๐๐๐จ๐ฅ๐๐๐ฉ ๐ฉ๐๐ ๐ง๐ค๐ก๐๐จ ๐ค๐ ๐ผ๐๐๐พ, ๐ผ๐๐๐ผ, ๐ผ๐๐พ๐ผ, ๐พ๐๐พ, ๐๐ฝ๐พ๐พ๐พ ๐๐ฉ๐
Good leaders are respectful of & defend the roles of regulators & industry bodies when being discussed within their organisation.
They acknowledge the role & critical governance & independence of regulators & industry bodies & accept their (review, report) findings with openness, to understand & learn and not to justify or defend the leaders own area of accountability.