Posts Tagged ‘compliance’


 Geert, thank you for participating in our 2020 Trust Insights series. What is your trust insight?

Ethics and compliance officers need to stimulate and assist management to establish a culture of trust.  Geert Vermeulen





Can you expand a bit on this important insight?

If you want to create a culture where people feel free to speak, hold people accountable, managers set a good example, where employees are engaged with the organization and feel that they are treated fairly, you are basically working towards establishing a culture of trust. This means that as management, you should not only focus on satisfying shareholders, but also on your other stakeholders, starting with your employees.

By establishing a culture of trust, where people are not afraid to admit errors and mistakes, are able to challenge decisions, where they openly discuss potential problems as well as new ideas, you will not only have fewer long-lasting problems but you will also stimulate a more innovative culture. As a result, you will have a better reputation as a company.

Therefore, you will be better able to attract high-potentials to come and work for you and clients will be more inclined to buy something from your brand. And as a result of fewer problems, more innovation and a better reputation, you will see that you will have better financial results in the long term. So, in the end, this also benefits your shareholders. It’s a win-win situation in the long term.


Can you provide a real life example of a trust “challenge” where your insight has been effectively applied.

I was working as an ethics & compliance officer at a multinational and found out that in a certain country people were making corrupt payments. We stopped the payments and asked an outside party to conduct an investigation. Unfortunately, the quality of the investigation was unsatisfactory and in the end, I decided to continue the investigation myself together with a colleague. So, we traveled to this country to interview people, analyze what had gone wrong and submitted a report to the management in which we advised to take a number of corrective and preventive measures, including firing a few people and taking disciplinary measures against others. Virtually all of our recommendations were adopted. As a result, people in the local organizations looked at me as the guy who got their colleagues fired and were frightened to talk with me. But that is not what I wanted, I wanted people to come to me with their challenges and issues, so we can have a discussion and try to find solutions together. We, (the management and I,) basically had to restore trust. But the question was how. We decided to use all the tools that we could think of.

We started by confessing that we (regional/global management and the compliance department) had also dropped the ball and had not been sufficiently involved in this country, despite the fact that it was identified as a high-risk country. Therefore, we invested in the local compliance function and I also visited the country more often. We encouraged everyone to come forward with anything that had happened in the past that they were concerned about, trying to create a culture of openness and transparency. And if they had not been the main driver behind the unethical behavior, they would not get fired or face any negative consequences whatsoever for coming forward. We offered all employees free access to external lawyers for a number of days. They could ask confidential advice and we would pay for that, without knowing who asked what.

Now that the corrupt payments had been stopped, some of our employees received death threats from former clients. After a careful deliberation we decided to step into that discussion, taking away the authority to make payments from the local country office and by communicating that if anyone still had problems with that, they could have a discussion with somebody from the head office (me), herewith exposing ourselves to these threats as well, demonstrating personal commitment. I have to admit that, since I have children, I have become less brave and more careful, so this was quite uncomfortable. Luckily nobody showed up to have that discussion.

We personally visited some of the more problematic locations to actually see with our own eyes what was going on. We organized dilemma sessions with the employees to explore potential solutions and panel sessions with senior management where employees could ask anything. At the same time, we launched a marketing campaign, organized a compliance quiz and handed out rewards. And to conclude the marketing campaign, we organized a party.

We knew that we would lose a number of clients and were prepared to make a loss. Much to our surprise our experience proved that, as we profiled ourselves as the most compliant supplier in the market, we obtained new clients and our annual results in the end actually showed a growth of both revenue and profit. We put a lot of effort into restoring the trust and I think that we managed to succeed. That said, keeping the trust also requires a lot of work and is something that should not be taken for granted.


Generally, do you think the global “trust” climate is improving or worsening? What actions are making it better or worse?

This is a difficult question. If I look at the political climate across the world I am not very positive. I notice that quite a few leaders with a nationalist agenda are elected, taking protective measures. Not trusting other countries. Blaming the opposition. 

At the same time, I also see changes in the business world, like the recent emphasis on ESG, as expressed by BlackRock and other major investors, as well as the declaration from the Business Round Table in the US. Business leaders are realizing that they are losing credit from society and they release statements that they want to balance the interests of the shareholders with the interests of the other stakeholders. But do we see that happening in practice? I guess it is still too early to tell. In The Netherlands we have seen leaders like Paul Polman from Unilever and Feike Sijbesma from DSM making their companies more sustainable and at the same time also delivering better business results. The question is what their successors will do now that they have stepped down. And whether other companies will adopt a similar strategy.

More importantly, I am very optimistic about the younger generations, the millennials, who seem to have another attitude. In the US we have seen employees starting protests against their companies who don’t seem to follow their own value statements. I have not seen that in other countries yet, but I do notice (anecdotally) that also in Europe the young generations are less interested in money, possessions and wealth and more interested in experiences and doing something meaningful with their life.


Many claim we have a crisis of trust. Do you agree?

Yes, I do. Countries seem to be less inclined to support each other. Free trade agreements are re-negotiated. The value of international institutions is challenged. We spend less money on development aid. The US and Europe stop refugees who want to enter their countries looking for a better life. We have free movement of goods and capital but not of people. If anything bad happens, foreigners are blamed. In the US the Democrats and republicans are so divided that it is hardly impossible to reach a compromise. This while a good democracy also takes the interests of the minorities into account.

Instead, we see an ‘us against them’ attitude and people hardly seem to be able to listen to each other, feel empathy with other people, trying to understand their situation and line of thinking. And this happens at a time where we are more connected than ever through social media and global supply chains. The reality is that we are all in this together. Trust in vital institutions like journalists and scientific institutes is waning. However, I also see some positive trends, as described above.


Geert, how has your membership in our Trust Alliance benefitted you professionally?

The Trust Alliance inspires me. I learn from other people and it is always nice to meet likeminded people to exchange thoughts and ideas. I have also used the outcomes of the FACTS(R) Framework to support my theory that ethical/trustworthy organizations achieve better business results in the long term. I use that in my articles, talks and training sessions.

In The Netherlands I have been active in the Association of Dutch Compliance Professionals. I am the former Chairman. I launched and still chair the expert group on Financial Economic Crime and am a member of the expert group on Culture and Behavior, where I lead the internationalization effort. This last group developed a toolbox with some 40 tools that ethics and compliance officers can use to (assist management to) influence the company culture and the behavior of individuals. We are going to include Trust Across America-Trust Around the World’s AIM Survey tool in our toolbox this year.


Geert, thank you so much for your time and more importantly for your commitment to elevating organizational trust. What would you like our audience to know about you?

My mission is to help organizations conduct business in an ethical and compliant way by reducing risk and stimulating better business. I specialize in establishing and improving ethics and compliance programs in general and anti-corruption programs in specific. In 2016 I founded ECMC: Ethics & Compliance Management & Consulting to provide compliance training, consulting and interim ethics & compliance management. I also speak and write on ethics and compliance.
Most of my experience was obtained in-house as the Chief Compliance Officer Aon EMEA and the Global Head of Compliance of Damco, the freight forwarding arm of Maersk. I have been the President of the Dutch Compliance Officers Association, the founder/chair of the expert group on Financial Economic Crime of the Association, a member of the expert group on Culture and Behavior and a member of the Professional Advisory Committee of the Law Compliance Minor at The Hague University. I am the recipient of the 2020 National Compliance Award.


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Did you miss our previous 2020 Trust Insights? Access them at this link.

Contact us for more information on elevating trust on your team or in your organization or email me directly:

Copyright 2020, Next Decade, Inc.

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Ideally, an internal C&E team will have great people skills and the ability to communicate and collaborate with all stakeholder groups. But if the team is ignoring the underlying principles essential to building high trust, the C&E function will be ineffective AND responsible for increasing enterprise risk.

Barbara Brooks Kimmel, CEO Trust Across America-Trust Around the World

The head of Compliance & Ethics at a large global public company recently engaged us to administer our AIM Towards Trust assessment within their 20+ member team. Unlike others who take trust for granted or consider it a soft skill, this one acknowledged that internal team trust was lacking and wanted to find out why. They sought to identify trust weaknesses and strengths, and to begin a trust discussion with the goal of remedying the weaknesses, celebrating strengths and reducing risk.

Our one question/one minute assessment is based on our universal principles called TAP (Tap Into Trust), developed over the course of a year by many of the world’s leading trust scholars and practitioners, accessed almost 65,000 times, and now in use in dozens of teams and organizations.

The survey results are displayed below. Accountability, Transparency and Respect were identified as the principles that needed immediate attention and, armed with this knowledge, the C&E Team leader was provided with additional do-it-yourself tools to address the weaknesses.

This leader believes that the responsibility to elevate organizational trust lies with their team, and is now expanding the assessment, bringing it into other functional areas within the organization to identify and remediate trust gaps. 

High trust C&E teams are role models, supporting employee and customer wellbeing which, in turn fosters faster company growth and achievement of organizational goals, while minimizing risk. 

What do you think the trust profile of your C&E team would look like, or would you rather not know?

While your colleagues are embracing trust as the NEW currency, are you choosing to ignore it?

Barbara Brooks Kimmel is the CEO of Trust Across America-Trust Around the World whose mission is to help organizations build trust using a proprietary assessment tool called AIM Towards Trust. A former consultant to many Fortune 500 CEOs and their firms, Barbara also runs the world’s largest global Trust Alliance, and is the editor of the award winning TRUST INC. book series and TRUST! Magazine. Barbara holds a BA in International Affairs and an MBA. For more information contact

Copyright 2019, Next Decade, Inc. No part of this document may be reproduced without permission.



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It’s almost Week #4 of 2016. This is the fourth article in a series of weekly ideas to elevate trust in your organization, pulled from our third annual 2016 Trust Poster, 52 Ideas That You Can Implement to Build Trust.

This idea is offered by Mark Fernandes. As Chief Leadership Officer at Luck Companies, Mark has been charged with taking its mission of Values Based Leadership (VBL) around the world. @MarkSFernandes

Build cultures of commitment vs. compliance where choices are guided by values not policies.

For leaders, trust and relationships are the means and end of our work. Over the course of my career I’ve found that with them, all things are possible. And much like many other things in work and life, it’s what you do before you do what you do that matters most in building trust and relationships; and ultimately cultures that are guided by values and rich in commitment, vs. those that are guided by policies and steeped in compliance. As such, I would recommend the following:


By definition authenticity means something is genuine or real, and worthy of acceptance or belief. Kouzes and Posner subscribe “people won’t believe in the message until they believe in the messenger.” 


Booker T. Washington said, “few things can help an individual more than to place responsibility on him, and to let him know you trust him.” 


My version of this is to love your employees to death, give them something to believe in, and obsess every day about them becoming everything they are capable of becoming.


People want to know you are completely there with them, in this moment. Pour yourself into their lives and catch them in the act of doing extraordinary things. 


Employees place their precious lives in our care, tread lightly.


How many readers took took the advice offered in January in our Weekly series?

Week #1 Kouzes & Posner 

Week #2 Bob Vanourek

Week #3 Barbara Kimmel

Ignoring organizational trust is similar to swimming in an ocean with no lifeguards on duty. Do so at your own risk!

Barbara Brooks Kimmel is the CEO & Cofounder of Trust Across America-Trust Around the World whose mission is to help responsible organizations build trust. She facilitates the world’s largest membership program for those interested in the subject. Barbara also serves as editor of the award winning TRUST INC. book series and the Executive Editor of TRUST! Magazine. In 2012 Barbara was named “One of 25 Women Changing the World” by Good Business International.

Copyright 2016, Next Decade, Inc.




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What happens when a group of openminded trust, ethics and compliance experts meet for lunch to discuss the intersection of the three disciplines?

One of the tasks at hand was to create a visual representation of the functional interaction between compliance, ethics and trust in an organization.



Copyright (c) 2015, Next Decade, Inc.


What does this mean?

Compliance: While organizations require compliance as a minimum “rule setting/obeying standard,” compliance does not necessarily have an ethics OR a trust mandate. Compliance is merely the starting point, not the end. In fact, it can be trust’s worst enemy when it is assumed that compliance encompasses trust and ethics. Compliance is regulated while ethics and trust are voluntary. In most companies, this distinction is not made and the C&E Officer is usually an attorney who simply enforces the “laws.” He or she may have no understanding of ethics, let alone trust.

Ethics: The “character” component of trust is ethics, and unlike compliance, it is a personal choice. It’s the individual and organizational value system that must be debated, decided and set in place by the Board of Directors, not the CEO.  A Chief Ethics Officer, not a C&E Officer, is the distiller of these values. He or she need not be an attorney. So what role does trust play? Unfortunately, both individuals and organizations can be “ethical” without being trustworthy because there are two more attributes that must be present for trust to flourish.

Trust: In order for an individual or organization to be trustworthy it must, at a minimum exhibit not only character (ethics) but competence and consistency in all internal and external relationships. “High trust” companies understand the distinction between compliance, ethics and trust. Going beyond compliance and ethics by adding the trust component results in:

  • Less need/emphasis on compliance and it’s oppressive laws and regulations
  • Greater employee satisfaction and lower turnover
  • Faster decision-making and innovation
  • Less risk and fewer crises
  • Better relationships not only with customers but all stakeholders
  • A happier workplace
  • Higher profitability

Companies that understand the distinctions described above and embrace trust as a business imperative are beginning to hire Chief Trust Officers (CTrO), and for good reason(s). They are the “keepers of the golden ticket,” and perhaps the organization’s most valuable employee.

Barbara Brooks Kimmel is the Executive Director of Trust Across America-Trust Around the World whose mission is to help organizations build trust. She runs the world’s largest membership program for those interested in the subject. Barbara is also the editor of the award winning TRUST INC. book series and the Executive Editor of TRUST! Magazine. In 2012 Barbara was named “One of 25 Women Changing the World” by Good Business International.

Our annual poster, 52 Weeks of Activities to Increase Organizational Trust is available to those who would like to support our work by making a small donation.

Did you know we have published 3 books in our award-winning TRUST Inc. series. They are yours when you join our Alliance.

Copyright 2015, Next Decade, Inc.


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Virtue is more to be feared than vice, because its excesses are not subject to the regulation of conscience.—

Adam Smith


Yesterday I was speaking with a friend who recently changed jobs and is now employed by a public company.  We were discussing how the new firm requires more dotting of i’s and crossing of t’s in justifying business expenses.  I immediately pictured Oz behind the curtain saying something to the effect of “Prove to me that all your expenses are justified,” and then I envisioned all the layers of bureaucracy (and payroll expenses) that feed this “control” process monster screaming, “We can’t trust you to do the right thing because our regulations don’t allow us to.”

And then today, another acquaintance wrote a piece on LinkedIn Pulse called Smart Compliance Doesn’t Require Mega-$ or Armies of People. I was excited when I first read the article’s title, but that quickly faded. Imagine having 10% of your employees dedicated to compliance? The author makes the argument that financial firms in particular need  “Smart, integrated compliance, risk and reputation management that creates organizational resilience and sustainable success.”

Taking this argument one step further, even in financial institutions, integrated compliance, risk and reputation management costs will be even lower when organizational trust is high. It may not be regulated, but that doesn’t make trust soft. In fact, quite the opposite. As we have recently shown in our new magazine TRUST!, industry is not destiny, even in financial services. What if we surveyed the financial institutions mentioned in this magazine issue to determine what percentage of their employees are dedicated to compliance, and how much their employees feel bogged down by bureaucracy? The business case for trust has already been made and I’ll bet the survey would further support it.

Good luck to those firms who are bogged down by bureaucracy and compliance. They are spending their money in all the wrong places. What do you think? If you work in compliance, risk or reputation management, please weigh in.

Barbara Brooks Kimmel is the Executive Director of Trust Across America-Trust Around the World whose mission is to help organizations build trust. She is also the editor of the award winning TRUST INC. book series and the Executive Editor of TRUST! Magazine. In 2012 Barbara was named “One of 25 Women Changing the World” by Good Business International.

Nominations are now being accepted for Trust Across America-Trust Around the World’s 5th annual Global Top Thought Leaders in Trustworthy Business.

PrintND Trust CEO cvr 140602-ft914Trust front Cover

                                                                                                 Coming Soon!

Should you wish to communicate directly with Barbara, drop her a note at

Copyright © 2014, Next Decade, Inc.

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How often do you hear one of these statements?

“I need to get approval to do (or say) that.”

“I need to clear this through compliance.”

“You can’t quote me if I don’t get permission.”

“I can’t help you without approval.”

Have you ever considered the relationship, within an organization, between approval and trust?

I’m not referring to the first definition of “approval” from Merriam-Webster, but rather the second shown below.

1. The belief that something or someone is good or acceptable: a good opinion of someone or something

2. Permission to do something: acceptance of an idea, action, plan, etc.

Think about how many employees are constrained by an “approval process,” and how this impacts speed of innovation and decision-making as well as employee engagement. Think about how costly this is. Every time someone needs approval to say something or do something, the “approval” process impedes the outcome. In fact, the process may be so daunting, that employees choose to take the “easy” road, never creating anything new or suggesting a new idea. After all, it would require approval.

What if leaders chose to extend trust throughout the organization by never requiring approval for ANYTHING?

Instead CEOs and their Boards took the time to craft long-term credos, vision and values statements and/or Codes of Conduct; and they were more than just “slogans” etched into the wall at corporate headquarters. The entire staff, starting with the CEO, lived the values every day, and employees understood, at the time of hiring, that any “values violation” would result in immediate termination. Now imagine the innovation, speed of decision-making and empowerment that would come from this cultural transformation. Imagine the cost savings.

During the editing process of our new book Trust Inc. I spent time searching the websites of several large public companies. The goal was to include an Appendix of examples of well-crafted values statements. I was surprised at how difficult they were to find online, and when I did, most of them were “just talk” or empty words. The few I did locate could not be included as written without “approval” from the respective company’s legal department. This would have delayed the publication of the book by several months (not days.) I did a “work around” of the approval process, eliminating the company name.

If organizations spent more time building values instead of  layers of legal teams and compliance departments, the word “approval” would start to look more like Merriam-Webster’s first definition: The belief that something or someone is good or acceptable: a good opinion of someone or something. 

The word “approval” would start to look more like trust.

What do you think? Please feel free to leave a comment or send me a note at

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