Q&A: Deloitte's Ethics and Compliance Watchdog

"It isn't a career, or role, that you work at alone. There's a lot of cooperation, so you need to be comfortable working with several disciplines."

Harold Tinkler has been with Deloitte & Touche for 35 years, and has held the chief ethics and compliance officer's job since 2003. He oversees the development and execution of ethics policies applied both internally and externally. Previously, he was managing partner for the firm's Connecticut audit practice, as well as a senior technical partner. For 23 years, he was an audit partner for Deloitte in New York.

First, how did you become Deloitte's chief ethics and compliance officer, and could you describe your role?

As a professional services firm, we need to adhere to rules from professional and regulatory standpoints. Ethics are how you act when no one is looking. I've been with the firm for 30-plus years, the first 35 in the audit practice. I was an audit partner, a practice leader role in risk management for 15 years. Three years ago, the firm decided to consolidate the whole area under one person and created the role of chief ethics and compliance officer. I'm the first one to hold this position.

My role is an extension of my prior work here. I've been successful because I've been with the organization for a long time. I know the organization, the people and the issues we deal with day-to-day.

Ethics is not a case of choosing between right and wrong. In many cases ethical decisions carry competing risks, so it's determining which has the greatest risk. We try to make sure that people use the available tools or seek out help. My responsibility is to help my Deloitte partners resolve problems and administer responsibilities to encourage ethical behavior. We help develop tools and policies for the various practices, and we monitor them. My job is to create an environment and ensure policies are consistent and, of course, enforce them if necessary.

Ninety-five percent of my job is helping people, primarily when there are questions about issues, and figuring out how to deal with them. All of our ethics, compliance, and business-conduct practices are integrated into decision-making processes. We can recommend strategies to ensure appropriate business conduct and help employees choose the proper course of action.

What's a typical day like for you?

My typical day is broken down into two baskets: my internal day and my external day.

Internally, our primary tool is an ethics help line, an 800 number that people can call confidentially to ask questions about ethics and professional behavior. They can make a report on a matter that they think isn't right. We can develop resolutions, and often do, as the phone rings often and people know who I am. It lets people confidentially report on issues related to our ethical standards or ask questions if they have concerns over a policy, without fear of retaliation.

Externally, we have outreach programs, including speakers at universities and members of the financial community. The help line allows us to deal with ethics and compliance matters effectively.

What advice would you give to people interested in compliance as a career?

To be successful in compliance you must be able to develop a deep expertise in areas that you oversee. It requires the ability to relate to people and complex issues that are subject to compliance monitoring - many of which are client matters. You have to have a mindset compatible with quality control. The work should be the primary motivation.

It isn't a career, or role, that you work at alone. There's a lot of cooperation, so you need to be comfortable working with several disciplines, such as human resources, professional, legal, personnel. It also requires an understanding of client relationships. There are a number of web sites and professional associations that are good resources for ethics and compliance work. One is the Ethics and Compliance Officer Association. It's very important to possess a strong sense of "team."

A lot of questions come up, so you can't simply teach people about compliance and ethics. It requires more of an ability to make them aware of the issues they'll face. Most people never intend to do be unethical or non-compliant. It's that the workplace is complicated. There are many gray areas when it comes to understanding what the requirements are and how employees go about fulfilling them. This is where I can help. I can help navigate through better approaches. It's my job to make them aware, and provide a resource for people to go for assistance.