In 2008, I had the pleasure of interviewing Hoffman while he was visiting Rochester, New York. I asked him about the early days of the business ethics movement and his assessment of the impact that the compliance and ethics profession has had on the business community. After learning of his passing, I retrieved my notes from that interview, which are partially reproduced in this article.

The professionalization of the field of business management seems no closer today than it was 10 years ago. For those of us in the business of promoting ethical business practices, the reasons for this are worth exploring.

It is hard to find evidence that corporate compliance and ethics professionals and corporate counsel are having a measurable positive impact on performance. Although we have produced policies, procedures, controls, and training programs by the truckload, we have failed to reduce criminal misconduct in the corporations we serve. A change in tactics and focus is required to achieve a different result.

Moreover, as often as not, I’ve observed that corporate executives outside of the law department and other corporate functions generally lacked an understanding of existential legal requirements that, if transgressed, threaten the company’s survival.

The key to achieving strong ethical cultures is as simple as it is difficult to achieve; strong ethical leaders at the top. Decades of work by social psychologists have consistently demonstrated that we follow our leaders. If they are corrupt, we are corrupt. If they are virtuous, we are virtuous.

Regardless of how well-intentioned or well-written they might be by themselves, corporate mission, vision, and values statements have no impact on employee behavior. Although people do not respond to slogans, they do respond to leadership.

Abandon the myth that policies and procedures drive behavior, and exert whatever influence you can to hold your leaders to the highest ethical standards. Experience has shown that when our leaders are corrupt, we become corrupt.

Despite their possible shortcomings, performance metrics — including profit and loss — are vital to helping businesses track and report results to shareholders. The question is, how can we craft meaningful performance metrics that incentivize desirable behaviors while avoiding potential negative consequences?

It is not enough for business professionals to just have an academic understanding of operational priority rankings. They must exhibit what DeMarco refers to as the five attributes of a “Good Will Leader.”

Like modern aircraft, businesses have a level of complexity that exceed any one person’s ability to manage without well-designed procedures to check the status and performance of critical systems. This is especially true for multinational corporations that must find a way, every day, to navigate a hazardous and byzantine legal landscape.

As governments around the world enact and enforce ever stricter anticorruption laws, the need to effectively manage sales intermediary corruption risks has become more important than ever. Although it is impossible to eliminate such risks, you can reduce them by implementing the following six essential elements of an effective sales intermediary anticorruption compliance program (ACP).

Our commitment to conducting business in a lawful and ethical manner is not tested when doing so is easy, but rather when it is hard.

I think it is important for board directors and corporate leaders to face reality. Either acknowledge that their CCO is merely heading another corporate function with narrow responsibilities, or (and I prefer this option) empower them to also provide oversight for all corporate functions that manage legal and ethical risks.

We can optimize our chances of success by helping our colleagues achieve a level three understanding of the rules and striving to engage them in the learning process.

If you are in a leadership position now, consider whether you may be falling into the trap that has caught so many others by taking liberties with the rules that you would not tolerate in your subordinates.

There may be occasions in which compliance with the law is not the highest ethical priority.

If such a massive scandal can happen at Wells Fargo in a tight regulatory environment, it can happen anywhere. The automotive repair industry and important discoveries in social psychology, however, point the way to some answers.

By generating these metrics, the ECI focuses its attention on what matters most — the key social dynamics in organizations that drive behavior. These are far more important than policies, procedures, or internal controls. There are written rules and then there are the real, cultural rules embedded in the organization that everyone follows.

If you really want to get serious about better managing these risks, find a way to work with your leadership to implement a systematic approach to measure the effectiveness of the systems you and your organization are counting on to stay out of trouble.

However, there was a fundamental weakness [in our financial controls] that we had failed to account for — the tendency of even the best financial professionals to follow what their boss tells them to do, regardless of whether it contradicts the rules.

Like pilots, corporate counsel and the management teams they serve are just as prone to the myopic preoccupation with fixing things that have gone wrong.

You don’t have to be a CEO to be a purpose-driven leader that looks beyond the bottom line to inspire the best in others. Every company leader — including those of us in the legal profession — can do this by making the effort to expressly identify the good that will come to others by a job well done.

If you were asked to do so, how would you go about quantifying your company’s compliance and ethics risk tolerance in terms that would provide actionable intelligence to your leadership team?

I think it is vital to look for opportunities both large and small to change or alter habits and to strive to achieve a greater capacity for self-regulation in the face of life’s challenges with the object of realizing our potential as authentic, ethical leaders.

Your fate and your company’s fate depend on whether you and your colleagues have adopted and mastered a practical approach to navigate a complex moral minefield where one misstep can end a brilliant career. Moreover, firms that successfully integrate moral considerations into their decision-making processes lower their enterprise risks and optimize business performance over the long term.