Ep.8: Out of the Echo Chamber

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About this episode. This series is all about curiosity in the search for “better ways.”  And that search has taken us to some unexpected places: we’ve talked to an award winning actress; data scientists; AI ethicists; behavioral scientists; psychologists; lawyers; an auditor; and many others. We’ve also drawn inspiration from congress, religion, academia, the military, sports—and of course, from the world of business.

In this episode, Zach and Hui talk about the importance of getting out of the traditional culture, compliance, and ethics “echo chamber”; why many of the most prominent conferences on these topics (and it seems like there’s been a lot lately) fail to deliver; and they each share three unexpected sources of inspiration (from pop culture to 15th century history to modern medicine). And most importantly, they get specific; about how each of these areas inspire them—and what they teach us about our work.

Who? Zach Coseglia + Hui Chen, CDE Advisors


Full Transcript:

ZACH: Welcome back to The Better Way? Podcast brought to you by CDE advisors. Culture. Data. Ethics. This is a curiosity podcast for those who ask, “There has to be a better way, right? There just has to be.” I'm Zach Coseglia and I am joined, as always, by Hui Chen. Hi, Hui.

HUI: Hi, Zach. Hello everyone.

ZACH: Welcome back to The Better Way?

HUI: Yeah.

ZACH: We are going to just do this, you and I today; and we have what I think is a pretty exciting topic. I don't quite know how to frame it except to say that what we really want to talk about today is getting out of what we sometimes call the “compliance and culture echo chamber.” And for me, that means looking for inspiration in maybe unexpected places.

HUI: I'm a big fan of that approach because I often see people, not just in the compliance field, but in every field that I've been part of, they tend to just talk to the people in that field and often times they talk to the same people; they talk about the same topic; they're looking at approaches they're all familiar with; and nothing really new and fresh is being injected into those conversations. And by looking outside of that echo chamber, I think that's where I really do often find inspirations.

ZACH: 100%. I mean, in a way, it's sort of the core point of this podcast is: the search for better ways often takes us to people and places that we might not otherwise find—at for example, your average compliance conference. And that's exactly what we want to do today. And, you know, Hui, while we're on the topic of compliance conferences, I think it's worth sort of addressing how those events can actually sometimes be the kind of echo chamber that we want to get away from. Obviously, the best part about going to compliance conferences is seeing people from our community; is seeing friends and colleagues or former colleagues.

But sometimes, the content at those things can be the kind of “people from within the discipline sharing information with people within the discipline” that doesn't necessarily move or advance the ball as much as we'd like it to. And in fact, part of the inspiration for today's discussion was, not being at, but hearing about the content at a number of recent compliance conferences—and feeling like we, as a discipline / we as a profession could do better in both who we look to for inspiration, who we bring to the table to have these conversations and how we work together to share new information and think about the work that we do a little bit differently.

HUI: I think that's so true that the only reason, I think, most people go to these conferences now is to see their friends and colleagues. That really has become the only draw for many of these conferences; and you know, I have experienced this frustration with the content for many years now. And one of the problems, and this is not a secret, that many of these conferences are pay to play conferences—that . . . in the sense that . . . the speakers are people who pay for sponsorship and as part of your sponsorship package you get speaking slots. And then you have conference attendees who also pay, which is a very terrific business model for the conference organizers (which is I think it's ingenious). But I think what you do get is: the people who can bring fresh perspectives and the people who are truly groundbreakers in fields—that are, may not be strictly compliance, but very much have relevance to our field—they are not going to pay to speak at our conferences. That is just not something they're going to do. And as a result, that model prevents those fresh perspectives and true expertise from coming.

ZACH: It's right. It's right. And look, the keynote at a lot of those, to take it in a slightly different direction, is often someone from the government, which can be really interesting and impactful; but also, you know, doubles down on this enforcement focused approach to our work, to the exclusion, I guess, of what we really focus on, which is a values, a human centered, a data-driven and evidence based, an outcomes, over output focused approach.

HUI: It's so true if you want to see any evidence of the compliance industry being driven by enforcement, just look at who's who are the keynote speakers at all of these conferences. They're always—not almost always—they’re always someone from the government or someone who very recently—within the, you know, 6 to 12 months preceding the conference had been in government. And I have never seen a real data scientist. I have never seen a culture anthropologist. I have never seen a CEO, a true CEO, a business leader who is not a compliance business leader—but actually, you know, leader of the kind of business compliance officers serve at. I've never seen any of them, not only as keynotes, but even as just speakers because let's face it, they're not going to pay to speak at compliance conferences.

ZACH: That's right. That's right. The one exception to that, which I'd like to take a little bit of credit for, is that the FCPA Data Analytics conference that often precedes the bigger FCPA conference: for years, it was just lawyers, including myself, who chaired that event and who spoke at that event. And finally, I said you guys should get a data scientist to lead this thing; and they did get our friend Tara Palesh to chair that event for two consecutive years, which was a huge improvement. I think the content benefited from it. That's the kind of person that should be, you know, a data scientist, maybe, leading a data analytics conference. I mean, it's not exactly a novel idea. Yeah.

HUI: No kidding. No kidding? Exactly.

ZACH: But look, I mean, this is partially why, as much as we want to see our friends in the compliance community, this is part of the reason why we often are very selective about which ones we go to. One, because we're a small business and paying to play is just never something that we're going to do; but also because Hui, I love what you often say, is that if someone is not getting paid to speak or if someone is actually paying to speak, you've got to ask yourself how much value is there and the things that they actually are going to say.

HUI: Exactly. And I do ask that. All the time.

ZACH: Yeah, yeah. All right. Well, look, let's move on from that and let's get out of the echo chamber; and let's share some places where we've been inspired outside of traditional avenues . . . outside of traditional compliance and culture. And we've each prepared three sources of inspiration. So, since I'm the one talking right now, Hui, I'm gonna throw to you and say, why don't you start? Give us your first one.

HUI: Oh, I thought you were gonna say you were gonna start, OK? Fine, I can start. So the first one, the first area that I'm gonna point to, which should be no surprise to anybody who's heard my analogies, which, you know, I love to make analogies.

ZACH: You do. Indeed.

HUI: It's often analogies relating to medicine.

ZACH: Yes.

HUI: So, the field of medicine is something that fascinates me. I have always said that I would be a doctor, but for the fact that I have four particular fears. Strong fears: that would be blood, vomit, biology and chemistry.

ZACH: Hmm.

HUI: That kind of rules me out of medical school; but does not diminish my interest in the field of medicine. And I would tell you a few reasons why I find medicine to be such an inspiration for me in my work in ethics and compliance. One is just the complexity and the mystery of human body, to me, is very analogous to the complexity and the mystery of human organizational systems.

So that . . . you know, you've heard me sort of make analogies about compliance programs to, you know, to human bodies. And I talk about things like, you know, doing compliance checkups, like you would do a health checkup.
I talk about how you do monitoring like doctors would do blood tests.

ZACH: Yes. Indeed.

HUI: And I do talk about these things because I really do find so many sort of really transferable concepts between the human body and the human system. The human social system. So that's one reason that I find it so interesting. The other is that, you know, medicine takes a very risk-based approach.

So, what do I mean by that? So the tests and the screening that they do, for example, are not the same. Smokers have different sets of screening—cancer screening—that would be recommended to them versus people who are non-smokers. They don't prescribe mammogram for everyone, regardless of gender. Mammograms are for women over certain age.

ZACH: Yes, I knew that.

HUI: It's because, right? So, this is this is very risk-based approach; and so, they don't do the equivalent of training and policy and whatever for everyone they actually distinguish—they look at who has what risks and they target their screening and their treatment, all of that, to those risk factors that vary from one population to the other. And I think a final reason that—well, not a final reason . . . I mean, a third reason out of many that I find this such a useful space for me to look at for inspiration . .  is the scientific approach. Now, granted, one of the things I love; one of the type of books that I love reading are history of medical science. And if you read enough of those, you would know that this scientific approach is really quite new. It's really within about the last 100 years or so we were still . . . we had a doctor who was going around the world doing lobotomies on people well into the 1950s. We were still having people, you know, letting blood as treatment for all kinds of diseases well into the beginning of 19th century. So, what changed was really the concept of “let's take a scientific approach to this; let's test things; let's see if we do it this way versus that way and control all the different other factors, how do the outcomes differ?” And so, this is basically the concept of clinical trials.

ZACH: Yes, yes.

HUI: We don't do that at all. We do, in the compliance space, we have been prescribing policies and procedures and training for all illnesses since time began. We have not tested what kind of training really works. We have not tested what kind of policy really works.

So in the compliance field, we have really only the very beginning of that approach in the work of Professor Benjamin van Rooj and the researchers who worked with him on the on the policy study; and also, Professor Todd Hall and Suneal Bedi in their wor on marketing and compliance values. So, those are the very beginning of those work, whereas of course medicine is about 100 years ahead of this. So, I would love to see more of the scientific mindset going into compliance, where we really try to test and see what we're doing, what is what works, what doesn't. So those are some of the inspirations I've gotten out of the field of medicine.

ZACH: I love it. I'm not surprised that that was your first area of inspiration, based on how frequently and eloquently, frankly, that you talk about the connection between the two fields. And I couldn't agree with you more on wanting a more clinical based approach to our work. We've been out there trying, and I encourage those who are listening, whether you’re compliance officers or whether you're businesspeople, to make space for this. Because it's the only way that we're actually going to know whether or not the things that we're doing are actually having an impact. And I think that folks sometimes get worried about the cost associated with it or the time associated with it. But when you step back and really think about it, what's better: spending a lot of time and money doing things that may not work at all—at best, you have no idea whether they work. Or spending, you know, time and money figuring out whether the things that you're doing are working so that you can stop doing the things that aren't and start making space for the things that do.

HUI: So true. So true. And I would mention also that if you're just listening and you want to know more about those studies, you can come to our website and in our transcript for the podcast, we will provide links to these studies.

ZACH: 100%. You know, and just before we move on, the other thing that I think comes to my mind when we talk about this is how many of our clients—and even, companies that we've worked for—are in the business of science.

HUI: Indeed.

ZACH: And their work, their revenue, their bottom line is all about doing this sort of thing on the product side, and yet it hasn't—in nearly all cases—permeated into compliance; and we talk all the time about wanting to have a seat at the table, about wanting to have respect and buy in from the business . . . well, what better way to get those things than to run your compliance group in the same way that they run their business? I feel like that's something they could really understand.

HUI: Oh, I think that's 100% true. And even if you were in a company that is not in the scientific field, I will wager that in your marketing department there is quite a scientific approach to their marketing campaigns. Because they need to know which channel is actually getting responses.

ZACH: Yeah. Yeah, 100% and we, we just talked to a[n] organizational psychologist who worked in corporate marketing on our last episode.

HUI: Yep.

ZACH: All right. Well, I guess it's my turn to share my first one.

HUI: Yes.

ZACH: My first one is much more tactical than the expanse that is inspiration from the medical field. But mine is being inspired by some of my recent travel.

HUI: Oh, I love that.

ZACH: And as you know, I've been sort of all over the place, working and holidaying in Europe and Northern Africa. I think I've been to 12 countries so far. I still have . . .

HUI: You're inspiring me.

ZACH: . . . a couple more—still have a couple more to go. And while there's all kinds of big, expansive ways that I could draw inspiration from travel—I mean, going to a different country every couple of days and experiencing that unique culture and seeing what connects us . . . but also what makes us so different. Right. I mean, there's big ideas in there; but I actually have a very, very tactical one. On part of my travel, I have been on a cruise ship. (Now I just want to say as a side note, anyone who turns their nose up at those who decide to travel on a cruise ship should think again. I used to be one of those snooty travelers; and we should stop it because it can be a very, very satisfying way to travel, if you pick the right one). Now on this ship, I get on, and on most ships, you have to watch a safety video. That's the first thing that you're supposed to do when you get to your stateroom.

HUI: Hmm.

ZACH: And when I got to my stateroom, the safety video didn't work because the TV didn't work. Now you're supposed to watch the video before the ship leaves the dock. But because of my TV malfunction, the video never played for me until I turned the TV on the next day. So here we are now, more than 24 hours into the trip and I have not gotten the required safety . . . we'll call it training. In fact, I didn't even know that I was supposed to watch it until the TV reset the next day; and it forced me to watch it. Here's what worked well. I repeatedly tried to mute the thing. It was 14 minutes long. So that I could just let it run without actually listening to it. Does that sound familiar? Does that sound like . . .

HUI: Very, very familiar.

ZACH: . . . what people try to do with their online compliance trainings? Well, here, it wouldn't let me. And frankly, that actually felt like a bit of a step ahead of a lot of the online compliance trainings that I see, where if you once you hit play, you probably could hit mute and walk away or go about your business elsewhere on your computer. Or in your office. But here's what I really liked about it. Now I may not have known this unless I actually heard it in the video, but they explained this to us— and it's important to know on a boat whether you're walking toward the front of the boat or whether you're walking to the back of the boat during an emergency. It's also helpful just to get around the boat. And to help us figure this out in a low tech way that isn't reliant on electricity, for example, in the case of an emergency, they chose a carpet pattern that has a very subtle—but once you know they're there, a very distinctive—set of triangles that always point toward the front of the boat.

HUI: Very interesting.

ZACH: So I will post a picture of this with the podcast (see link above)—to see these triangles, these arrows; and maybe it can be criticized as being too subtle if you didn't know that they were there and that's what they were. But from a kind of compliance and design perspective, I saw this as sort of a wonderful human centered control. It solves a problem without being intrusive. It also solves the problem without compromising the aesthetic of the ship and its design, it's sort of –yeah—it's seamless, it's elegant, it's integrated, it's just in time. And these all feel like things that we want in our compliance controls. You know, when we think about our trainings or when we think about our policies. And so, if I were to take the analogy a step further and think of the carpet, you know, or the design, as part of “the business” that we're always talking about in compliance, this is a control that is literally inside the business. And so, I just thought that was kind of wonderful.

HUI: I love it. So interesting.

ZACH: Yeah, yeah. I will have to show you. I will have to show you the picture because you'll see it and you'll be like, “oh, wow, yeah, yeah, that's exactly what it's doing.” And it's everywhere on the boat.  But you know, I'm, again, I'm not sure that I would have noticed if I hadn't been forced to listen to this video.

HUI: Well, leave it to you to find compliance inspiration on a cruise ship.

ZACH: And a carpet, I mean.

HUI: In a carpet. Yes. Indeed.

ZACH: All right. What do you got? What's next?

HUI: It's almost as if you knew where I was going next. I mean it.

ZACH: Interesting.

HUI: It's kind of scary. I was like, I can't believe he's saying this but my next one is: I often also look to safety industries. And you have heard also, I mean, none of this is a surprise if you're one of the people who have heard me or spoken with me pretty frequently. I do draw a lot of inspiration from the safety industries. Whether it's patient safety in the hospital—so this is overlap between the 1st and the 2nd areas of interest. There could be patient safety. I have made presentations that compare how patient safety is measured versus how compliance is measured. And it is a very good example of the outcome versus output that we have been talking about. So, in patient safety, the output measures are things like, did the surgeons and the surgical team wash their hands? Did they all do the sort of self-introduction that they're supposed to do? Did they train the patient on safety procedures? Did that train the personnel on safety procedures? All these are all the output. These are things you do in an effort to prevent something.

And then there's outcome measures, which is how many times bad things actually happened. So how many times did patients fall—[or] patients die due to infections? How many times did infections happen There is also how many times, believe it or not, I presented on numbers based on one of the best hospitals in the world; and there were multiple instances where surgical instruments are left in the patient after surgery. So that is not good for patient safety. So, they have all of these—they have all of these—both output and outcome measurements.

ZACH: That is not good, yeah.

HUI: They also overall have a very outcome-based approach because ultimately, it's about, if you're in patient safety, it's about how many patients died as a result of their surgery—or were further injured. If you're in aviation, safety is about, you know, how many crashes did you have or other sort of incidents did you have? It's very outcome based; and these are industries that are, by definition, very similar, if not identical to compliance, which is their job. These safety professionals in aviation, in patient safety, in public health: their job is to prevent, detect and remediate bad things happening—whether it's fatality, oftentimes injuries and fatalities.

ZACH: Yeah.

HUI: Our job in ethics and compliance is to prevent, detect and remediate misconduct. So, really, other than the last word, those two sentences that describe our mission are the same. Yet, these are industries where, when something goes wrong, people get injured. Or they die. Sometimes many, many of them. And they can't afford to constantly have bad outcomes, so they do measure their efforts. And boy, do they do have to measure their outcome because they can't, even in many cases, they can't even hide their outcome even if they want to.

So, if you look at public health system, they measure things like spending on preventative care. They measure things like vaccination, but they also measure overall outcome, like the mortality rate of your population. The disease rate of your entire population. They're looking holistically at those numbers to indicate whether they're successful at their efforts. So, I think that is an approach that, you know, really, I would like to see more of in ethics and compliance.  And the other aspect that I want to mention about safety is, I'm just going to use a story that that's from Malcolm Gladwell's Outliers.  And I think it's like Chapter 7 and it's about aviation safety and it's such an interesting story and you really should try to go read it. But I'll try to summarize it very briefly.

So, he's talking about aviation safety, and he cited stories of a couple of fatal plane crashes that killed hundreds of people. There was a Korean Air flight. And there was an Avianca flight that both crashed because of poor communication, resulting from a lack of awareness of the culture legacy that was operating in the cockpit. So, what happened was you have the Korean Air copilot knew that they were not taking the right approach in landing, but he, because of the cultural hierarchy in that existing Korean culture, and persists in the cockpit . . . he just didn't want to tell the captain that? So now think about it: this is not like—we tell people to speak up, but you know this is, he didn't speak up, and the result was he died . . . and hundreds of people died with him because he didn't want to speak up. He sort of like, you know, just said, “don't you think it seems to be raining a lot?” That was his way of communicating that in this weather condition, we probably shouldn't take this approach. Right.

ZACH: Yeah.

HUI: And then in the Avianca flight, they were out of fuel? They were literally that . . . the plane was perfectly fine. They literally ran out of fuel and dropped into the ocean. And again, you read the transcript and you just you see the copilot: same thing, same kind of hierarchical culture. He was like almost talking to himself very quietly when he was mentioning “we're out of fuel.” He mentioned it a couple of times, but at the end of other sentences and very quietly, almost like he's talking to himself. Both of these instances, because of the very hierarchical culture that persists in the general culture that they brought into the cockpit, that really literally caused 100s of people to die.

Now this reminds me of all the situations that we have encountered working cross culture. People say “oh, but you can't, you know, change the mentality of people in these other countries.” Whether it's in Asia, Latin America, Africa, wherever they say, “well, yeah, the local culture is this; and you can't change that.” Guess what? In aviation, they had to—because if they didn't change it, planes would keep crashing. So, what they did was they figured out a system. They called, which is now commonplace, cockpit resource management, CRM. CRM is a system that was developed to really address the communications issue in the cockpit and to overcome these cultural issues in communications. So, it's really by directly examining the culture legacy and confronting it with a methodology that they can give people a new identity. So, the idea is, yes, you may be Korean, Colombian, whatever—in cultures that emphasize greater collectivism versus individualism, greater sense of hierarchy and power. You may exist in that culture outside of the cockpit, but when you come into the cockpit, we give you a way to change that reality for your job. They can do that. Why can't we?

ZACH: Absolutely. And look, I mean, it's hard—not to say that it is easy; it's hard work, but it's such a powerful source of inspiration. What isn't hard though, on this same topic is just simply taking a more outcomes driven approach to everything that we do. And it seems like common sense, and it feels like there's nothing new in that idea, but I can't tell you . . . I mean, you know, how many people we talk to who still ask what is the difference between output and outcomes?

HUI: Yep.

ZACH: Who don't start a project by defining the desired outcome so that they can work toward it. Who create trainings without determining what those outcomes should be; and often, at the end, defaulting to—and this is so true still today, in 2025, default to “the percentage of people that took the training,” rather than any meaningful metrics about whether they learn something. And so, I think we have a long way to go on this front; but it is, I think, the future of our discipline . . . is taking inspiration from both of these things that you've shared and building a more outcomes-driven approach.

HUI: I think we have to.

ZACH: All right, let me share my second one. These are also, I think, very reflective of our personalities So my second one is, I guess, the broader source of inspiration for my second one is, is art.

HUI: I knew it.

ZACH: I did a silly post on LinkedIn a couple weeks ago about inspiration that I had from visiting the Picasso Museum in Barcelona. It was nothing groundbreaking, but I was inspired, nonetheless. But this one is going to be far less high art and more inspiration from popular culture—and that is one of my favorite TV shows, The West Wing. And the inspiration here—or the idea here—is pushing back on the notion that numbers don't lie. That when we take a data-driven approach, that the numbers give us truth. But in truth, truth can be tricky to find, even when we're dealing in mathematics, and especially if our analysis of the data is flawed or is careless; or if we're bringing bias to that analysis. For example, by having a specific story that we feel we need to tell and can't move past our own assumptions and agenda.

So, there's this episode of The West Wing titled Lies, Damn Lies and Statistics**, which itself is inspired by the saying popularized by (I'm not sure it was actually first said by, but popularized by) Mark Twain. “There are three kinds of lies: lies, damned lies and statistics.” And in this episode, the Deputy Chief of Staff, played by Bradley Whitford, is working with a political pollster to evaluate American voters’ stance on a five-day waiting period to acquire a firearm—or something like that. And the proposed legislation polled really well nationwide; 58% of people supported it. But it didn't poll well in five critical Midwest districts. And that's really all the Deputy Chief of Staff cared about. And so, he said to the pollster, “We're gonna need to dial down the gun rhetoric there.” And the pollster, who's played by the absolutely divine Marlee Matlin, asks, “Why not dial it up?” And the deputy chief of staff starts to respond by saying, “because these numbers just told us, you know, ‘dot dot, dot.’” She interrupts him and says, “You don't know what these numbers just told you. I'm an expert and I don't know what these numbers just told you.” His response was, “Well, numbers don't lie.” And she took him to school by saying that they lie all the time.

**Note: This is deeply embarrassing for Zach, as he likes to think of himself as an real West Wing triva master. But he got the episode title wrong. The exchange described actually appears in The War at Home.

And the truth is, numbers do lie all the time. They lie when we use numbers instead of statistics and analysis. They lie when we fall into the trap of correlation rather than causation. They lie when we use the wrong chart / graphic, depriving us and the reader of context and clarity. They lie when we bring assumptions to our analysis that aren't actually captured in the data.

So, what is there to learn here from compliance? Well, I think first is, we need to do more than just read numbers. We need analysis. But to do that, we need people analyzing the data who have a level of maturity and skill in analyzing data. I can't tell you how many people I still here say, “I went into compliance to avoid math” or lawyers who work in the compliance space, who say “math's not my forte.” We have to stop this. I've said it before on the podcast: we have to stop this; and if that is truly how you feel, then you need to hire someone to review the data, who actually can review it in a meaningful and skilled way. Make it your forte or get people for whom it is their forte. So, building better data analysis skills within compliance—or within, you know, HR teams who are managing culture issues—is so critical. It starts with having the right people analyzing the data.

HUI: I can't.

ZACH: The . . .

HUI: Oh, sorry, go ahead.

ZACH: No, no, no, go ahead.

HUI: I can't agree with you more. The common issue that I see is people confusing causation with correlation. And that is, you know, that I see that a lot in, particularly in some of the compliance literature and I just cannot begin to say how wrong that is. So you talked about a TV show. I remember the scene from House—of course, a medical show. And Dr. House was at the grand rounds in the morning and somebody made a presentation that confused causation and correlation; so, Dr. House looked around and said, well, look out there. How many people are drinking coffee? Well, lots of them—more than half of them; he says, “Well, then, drinking coffee makes you a doctor.”

ZACH: Hmm.

HUI: And so it, you know, this is the kind of confusing correlation and causation that we often see. But all the other issues that you talked about, to me, is just the ability to think and examine data in a critical manner—critical thinking is really what we're talking about.

ZACH: Yeah. Yeah, which leads to the second thing that I take away from it, which is we should look to data as a way to get more informed, but not necessarily to answer all of the questions that we have. In The West Wing example, there were multiple ways that you interpret that; there were multiple ways that you could act in response to that. Two of them were dialing it down or dialing it up. And so you may need to actually dig a little bit deeper into what the data means by talking to people—by doing things other than just relying on what the raw data, the transactional numbers are telling you. In the culture space, for example, it could be doing focus groups.
Or, you know, pushing yourself to explore an answer that may be less advantageous to your agenda. So, let's say that you have only five reports to your hotline and a company of 10,000 people. Well, one of the conclusions that you could draw is that we don't have a lot of issues. Another conclusion that you could draw is that we don't know if we have a lot of issues or problems. Maybe what people are telling you there is that they don't actually feel safe speaking up.

HUI: Exactly.

ZACH: You know, you see this in in in other contexts around financial transactional data. You know, we didn't have any violations of our policy—or there were no, sort of procedural mistakes that people made. And so, we get confidence that we must not have any corruption. Well, if you have someone who's trying to, you know, bribe somebody or engaging in corrupt activity, whether it's bribery, fraud, abuse, whatever—some form of financial misconduct . . . maybe they were smart enough to learn all of the rules so that they could get the transaction through in ways that wouldn't trigger some of those . . . some of those tests. So, you know, taking a contrarian view to the analysis of your data and forcing yourself to question whether or not the answer that you hope is there is in fact the answer—or whether or not there may be another explanation, I think, is really critical to reviewing the data.

HUI: I think what you're talking about there is critical thinking plus curiosity. Don't let your assumption be the answer.

ZACH: Yes.

HUI: Don't look at a trend, a number, a set of numbers, and say, “well, this must be what that means.” Dig behind it. Just really dig into it to figure out what it means.

ZACH: Yes, yes, I mean, yes. This is a curiosity podcast, and curiosity is the solution. I love that.

HUI: Yep.

ZACH: All right. What's your third one?

HUI: I swear, you know exactly which three are mine and in what order they are. And somehow this is perfectly correlated without prior coordination. So, I am going to say my third is Undercover Boss, the TV show.

ZACH: Yes.

HUI: Again, this is something that you know, that I've been fascinated with quite a lot. I'm not a big fan of reality TV shows, but there are two that I do find relevance in our workspace. One is Undercover Boss; and the other is Restaurant Impossible on Food Network, which I don't think is running anymore. But let me start with Undercover Boss. This is, for those of you who don't know the show, this is where usually a senior leader in a company—it could be the CEO or the founder, or like the Chief Marketing Officer, Chief People Officer—they get into some usually pretty horrible disguise, and they're sent to the front lines to work with their colleagues on the front lines to see what it's really like. Now, typically, to make good TV, a lot of this would be in the service industry: hotels and restaurants, sometimes also in manufacturing, because, you know, if you send them into a sort of white collar setting it’s really not that interesting to sit around . . . watch everybody sit the computer and work and or get on conference calls. So, typically, it's the type of industry where the frontline work is active and it's, you know, it's something that is suitable for TV. A couple of things that always comes out of it is the boss is oftentimes shocked at what is actually happening in on the front lines of their companies.

I remember more than once watching the boss in the middle of something . . . so, you know, a foreman or a sales manager would be telling, “This is how we do this thing here.” And the boss in disguise is saying, “No, it's not. I just spent millions of dollars buying a new system, put people through training devised policies so that we wouldn't do it this way. And now you're telling me this is how you're doing it?” So, so that reality of what gets rolled out from a headquarter and what actually gets done on the frontline there's a pretty vast gap sometimes between the two; and unless you go to the front lines and you talk to the people on the front lines—you spend some time with them—you're not going to know . . . or certainly not at the, you know, at the C-Suite level. They don't seem to know. One of the things that I always tell compliance officers is, you know, go be the undercover boss. You don't have to put on the horrible disguise, but you certainly can go talk to people. Just talk to people; and just get to know them. Get to know what, you know, how they're doing things. What do they find troubling? What do they find enjoyable? What do they find difficult and burdensome? And I think a lot of this shows me how little we understand other people's experiences and perspectives. And this idea of someone who is in the C-Suite, or certainly in a, you know, office setting getting out of their office to the front lines of their organization and really get their hands dirty, literally. And experience the frontline experience talking to the frontline people, I think it's something that can be very insightful for the person who ultimately gets back to the office and can make real changes that impact people in a good way.

ZACH: 100% I mean so much of the theme from all of the inspirations that we've shared today is getting away from your own assumptions—and this is such a, like, very practical . . . like, a real way that people do that. And they do it by the way, in absolutely terrible wigs and costumes that make anyone who believes that this person is not actually the boss in disguise . . . makes you really question their capabilities. But I digress.

HUI: Yeah, yeah. Yep. What about you? What's yours? You're a third one.

ZACH: All right. So, my third one, I guess the broader theme is history.

HUI: Oh, I love it.

ZACH: And the learning is perception as truth, which I'll explain. But I recently went to a series of talks by this UK crime writer named Diane Janes. So again, not a compliance conference, but a series of talks by this crime writer. She does both fiction and historical nonfiction. She also did a really wonderful talk, by the way, about the work and life of Agatha Christie. So, this is sort of the world in which she works is true and fictional crime of all sorts.

HUI: Fascinating.

ZACH: And one of the talks that she did was about the Princes in the Tower. This is the story the true story of King Edward the V of England and his younger brother the Duke of York, who were the heirs to the British throne of King Edward IV.  They were his only living sons at the time of his death. They were 12 and nine years old, and they were put in—they were lodged in—the Tower of London, I guess, by their uncle the Duke of Gloucester, in advance of the older one, the 12-year-old's, coronation to become king. Now no one knows for sure, as I understand it, what actually happened to them.  But the prevailing assumption has been, for hundreds of years, that they were killed—and that they were likely killed by Richard III to secure the throne for himself. But her talk is all about how we don't actually know for sure what happened.
And she shared all of these examples from just historical lore to contemporary artwork to just other accounts of their life and death that have informed, kind of, popular understanding of what happened to them . . . but that aren't actually grounded in truth and in some cases can actually be fully refuted through historical records. And what I thought was really inspiring about this was this notion of how perception can actually become truth.

So how do we connect that to our work? Well, I think perception becomes truth in our world all the time. And you know, this came up in a recent conversation with a client where we were talking about some culture work that we were doing. And you know, they said in response to a question, “Well, you know that's just wrong because we do X,Y, and Z to make sure that our disciplinary actions following an investigation are consistent, equitable, and fair.” And I said, “Well, perception is an alternate version of that truth.” What you say may be the case. You may do all of these things in an effort to ensure that disciplinary actions are consistent, equitable and fair, but that's not what people perceive. That's not their lived reality. And so, we have to manage for the perception, even though your facts show that that perception may be inaccurate.

We often encounter, for example, perceptions that compliance is the police. Now, that may not be true, and everything that the compliance group does, may be in furtherance of proving that to be untrue—but the fact that people perhaps feel that way means that we still have to manage for it. One of the things that always comes to mind for me is the perception, on the part of business, that investigations take too long. I've heard this so many times. I've been on the receiving end of this so many times. And it may not be true, but we've got to manage for the fact that this is the narrative that's being told, and we've got to use data to counter it. So you know, when we're dealing in this world of, you know, the intersection of compliance and culture, in particular, it's a really important to understand that we may have our own perception of the truth; but our audience may have a very different one. And we are going to have to manage their truth irrespective of how deeply we disagree with it.

HUI: So, I have worked with organizations where, when I am doing interviews and focus groups with employees, they're telling me how they're perceiving the company. So in one example, for instance, they were telling me that they feel like the company’s only real value is making money. That they don't really care about the employees. They don't really care about any of the other articulated values. It is all about making money and compliance is nothing but a charade. They were amazingly candid with me in sharing some of these with me in the interviews that I conducted. When I reported this to their senior leaders, they were shocked. They said these people must be living under a rock. Look at this thing that we just did that, you know, showed how much we care for our employees. Look at this other thing that we did that showed how much, you know, we were willing to forego our revenue in order to make the compliant and ethical choices. How is it that they can think this way? Well, don't blame them for living under a rock because if they're living under a rock, that's a rock you created. And this is what they believe. Your challenge now is how to dispel that belief that seems to be prevalent, certainly among the people I interviewed.

ZACH: Yeah. 100% It's a hard truth, I think, to swallow. It's a hard lesson to swallow, but it's so critical to being able to do this stuff successfully. I mean, we’ve got to put the people as we always talk about at the center of our analysis; and when we amplify people's voices, we've got to listen to what they say, even if we disagree with it. And we've got to manage it. We've got to react to it.

HUI: Yep, yes, yes, absolutely. Well, I think that was a very productive conversation outside of the Echo chamber.

ZACH: Well. This was yes, this was so much fun. I love leaving the Echo chamber with you, and thanks to everybody for listening. We'll be back on The Better Way in a couple weeks.

HUI: Well, it's been a joy as always. Thank you, Zach and thanks everybody.

ZACH: And thank you all for tuning in to The Better Way? Podcast. For more information about this or anything else that’s happening with CDE Advisors, visit our website at www.CDEAdvisors.com, where you can also check out the Better Way blog. And please like and subscribe to this series on Apply or Spotify. And, finally, if you have thoughts about what we talked about today, the work we do here at CDE, or just have ideas for Better Ways we should explore, please don’t hesitate to reach out—we’d love to hear from you. Thanks again for listening.

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Ep.7: Analyze This