There’s a growing movement to evolve compliance programs beyond rule-following and more towards a values-based, ethics-driven model grounded in integrity. It’s the right direction. But in my experience, too many of these efforts are launched before the culture is ready to support them.
You can’t embed integrity where values haven’t taken root. You can’t implement an aspirational framework in a workplace where values are abstract, inconsistently modeled, or quietly ignored.
As Deloitte’s CCO Transition Lab puts it, today’s compliance leaders are expected to act as “cultural architects”—but we can’t build on unstable ground. And as EY’s Global Integrity Report reminds us, the threat to integrity isn’t just noncompliance—it’s the gap between what leadership says and what it does.
Here’s what I believe is foundational before we even talk about shifting to an integrity-driven program:
- Values Have to Be Modeled-If leaders don’t live the organization’s values consistently, employees won’t either. Integrity starts at the top—or it doesn’t start at all.
- People Share When Culture Invites It -If speaking up feels risky, integrity doesn’t stand a chance. Employees need to trust that raising concerns won’t cost them professionally or personally.
- Make Values Actionable-It’s not enough to post values—we must help people see what integrity looks like in daily decisions and challenging circumstances.
- Ethics Belong Everywhere- Compliance Can’t Carry This Alone. Operational leaders must own and model ethics in their decisions and priorities. As V-Comply (a governance, risk, and compliance (GRC) technology company) states, CCOs create systems, but the impact depends on operational accountability.
- Listen and Adjust – When values aren’t landing, pay attention. Feedback isn’t a problem—it’s a chance to rebuild trust and get it right.
As compliance leaders, we’re often asked to drive transformation. But you can’t build a values-driven framework on a foundation that won’t hold. Because no matter how well-designed the system is, integrity can’t grow in sand.
The first job isn’t a rollout. It’s readiness. Before we plant the seeds of change, we must prepare the ground.
Where integrity leads, progress follows.
Signed with purpose,
Desiree.