I've spoken with compliance professionals whose programs look to have the right elements – a code of conduct, annual training, a hotline and a risk assessment tucked in a shared drive somewhere. Yet they still face situations in which people don’t behave as they should. The question is why.

December 2025 was one of our town’s coldest and snowiest in recent history. Despite sinking $35k to upgrade our heating system with an energy efficient heat pump, it didn’t stand a chance against a house that has virtually no insulation. And a house without insulation is like a company without an ethical culture.

Responsible homeowners know that regular maintenance of the roof is crucial in keeping away snow, wind and rain. Responsible companies too, understand the importance of an effective ethics and compliance program in fending off compliance risks and ensure that their programs are well-built and well-maintained.

The employees we most need to reach are not seeking out compliance messaging. They are busy, distracted, and operating in a world where our messages compete with everything else demanding their attention. To get across, we need to meet employees where they are rather than where we wish they would be.

Recently, I came upon a work of art by David L. Johnson titled Rule at the Whitney Museum in New York City. It shows a collection of plaques from privately owned public spaces around New York City, where developers create these park-like spaces for public use in exchange for rights to build taller buildings.

How do we draw parallels between this artwork and a good ethics & compliance program?