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Bringing employees on board is essential for compliance strategy

The CCO of 3M shared some insight into how to pinpoint behavioral change for employees when it comes to compliance, instead of just providing information

While compliance cannot be overstated as a vital component of a company’s strategy and structure — particularly financial organization — having a program to ensure a company’s compliance and actually putting it into practice are two different things. Getting employees on board is part of the challenge. But the chief compliance officer of 3M has offered some insight into how the U.S.-based conglomerate has managed to reach employees through its compliance program.

The Wall Street Journal quotes CCO of 3M Jim Zappa, who took on the role of CCO in 2013: “What I think is important for me as a chief compliance officer is: are we continuing to have a proactive impact on our ability to grow the business and still meet all of our compliance and ethical obligations? Because if you don’t do both of those you are putting your business at risk, which is not at all the right thing to do.”

Zappa goes on to iterate that one of the important points of a compliance strategy is focusing on getting to “behavior” as well as supplying the information about compliance policies to employees. Changing the way employees view and accept compliance requirements is an integral part of establishing a well-oiled compliance system. 

He explains: “Information is great, but at the end of the day we want to get to behavior. That’s why we want to expand the number of local languages that our messages are deployed in. It means something for someone to experience the content in a language that is their own.”

3M is a company based in St. Paul, Minnesota that manufactures a myriad of products such as adhesives, laminates, car-care products, and some electronic equipment. While Zappa seems to have particular insight into how to create a most functional compliance strategy, the focus — especially in the U.S. — on the role of the compliance officer is set to increase over the next couple of years. The SEC has declared that it intends to hold CCOs more reliable for compliance issues within companies, which necessarily makes the role of the compliance officer more important, but also more risky.


Further reading:

SEC introduces crowdfunding compliance and disclosure interpretations 

GCs speak out on their 2014 risk and compliance concerns

Women may dominate the compliance officer field, but it should lead to other corporate opportunities

Contributing Author

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Juliana Kenny

Juliana Kenny is a contributor to, covering a range of topics including patent litigation, conflict mineral laws, executive compensation, and antitrust regulation. Juliana earned B.A.s...

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