A CEO’s words on ethics and integrity matter. The CEO sets the tone, signals the company’s integrity priorities, and determines how employees understand the company’s culture. A CEO’s public speeches, online statements, and inspiring declarations signal leadership’s commitment to integrity. While CEOs are essential, they do not exist in a vacuum, they are one part of an integrity system.

For compliance officers, this is where a stress test comes in. Compliance teams should test a CEO’s words against established policies, procedures, and employees’ firsthand experiences.  Misalignment here is a red flag. A CEO who emphasizes growth without discussing integrity and ethics sends a clear message, just as a CEO who emphasizes integrity and ethics but withholds resources for integrity initiatives.

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Run the Stress Test

Running a stress test on your CEO will give compliance teams information about the effectiveness of integrity systems. As a compliance team, this stress test should ask:

• Understanding the Risks: Does the CEO address the organization’s most significant risks?
• Employee Experience: Can employees identify the policies, procedures, and tools that support them? Or are employees confused about the priorities of integrity?  
• Hotline Data: Is the company’s hotline checked regularly? Are there reports that contradict the picture leadership paints? Are hotlines used as a basis for identifying emerging risks?
• Resource Allocation & Accountability: Do reports contradict the leadership’s perspective? Are there resources and tools that support integrity programs?

Answers to these questions will highlight gaps that require attention and focus.

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Pass the Stress Test

Regulators use effectiveness as the standard. They will look for evidence that the CEO’s words align with the organization’s policies, procedures, and resources. Compliance officers must be willing to ask hard questions and use the answers to those questions to improve and strengthen integrity.

Words alone will not protect a company from scrutiny. But when words and policy align, integrity is more than messaging. It is part of a company’s culture, and this is what will pass the stress test.