The Compliance Revolution: How Compliance Needs to Change to Survive

Chapter 7Outcomes¹

For the old Man—and 'tis believed by all

That many and many a day he thither went,

And never lifted up a single stone.

There, by the Sheepfold, sometimes was he seen

Sitting alone, or with his faithful Dog,

Then old, beside him, lying at his feet.

The length of full seven years, from time to time,

He at the building of this Sheepfold wrought,

And left the work unfinished when he died.

—William Wordsworth (1770–1850), “Michael—a pastoral poem”

This is the beginning of stage 5 of the General Model of Regulation and Compliance.

Why Is This Step Up So Significant?

Outcome changes everything. The introduction of this perspective should be taken very seriously by compliance, as it is a set of concepts that is revolutionary in itself and changes the fundamentals in regulation. The key changes are that outcomes-focused regulation and compliance:

1. Introduces a new set of criteria for judging the success of compliance
2. Requires compliance to use new forms of measurement within the business
3. Provides an additional perspective for making compliance decisions that necessitates compliance occupying a more strategic position

The key to the change is in effect looking from the other end of the telescope, at results and effects instead of processes and inputs. The shift is from the internal to the external: to consumers, potential consumers, and wider society at large.

This is not to say that prior emphases on capital, ethics, culture, governance, and conduct risk are less ...