Compliance Perspectives

By Adam Turteltaub

Steve Priest of Integrity insight International has been a part of the corporate ethics scene for decades now.  He’s worked with companies all over the world and is expert at assessing corporate culture.

In April 2019 we sat down for an atypical podcast.  Rather than dissecting one specific ethics or compliance challenge, we explored what’s concerning him these days.

The conversation began with a discussion of cellphones and how disturbing they can be, as well as the poorly understood data protection risks.

From there we moved on to the related and broad topic of another area where the understanding isn’t what it should be:  human psychology and behavior.  Steve argues that, for example, when it comes to training we tend to treat employees like children, telling them they shouldn’t do this or that.  He argues instead for a more prosocial approach, which goes hand in hand with the need to help employees better engage with the company.  That’s getting harder to do with so few employees staying with one employer for very long.

One potential solution for addressing these challenges:  get more professionally diverse voices in compliance, people with skills outside of legal and audit.

Along the way Steve also explains what he calls “The Three R’s” of putting in place a compliance program and the weakness of the fraud triangle.

Listen in and enjoy an illuminating and entertaining conversation.

 

By Adam Turteltaub

The European Bank for Reconstruction and Development (EBRD) was created after the fall of the Berlin Wall to help develop open and sustainable market economies in countries that were committed to and applying democrat principles.  To date, the EBRD has invested €130 billion in 5200.  Its focus is on private sector investment and supporting six market transition qualities:  competitive, green, inclusive, well governed, resilient and integrated.

Lisa Rosen, the bank’s Chief Compliance Officer, along with her team play a central role in helping the EBRD succeed in its mission.  It’s not always easy, she explains in this podcast, since many of the countries where the bank has investments have serious corruption risks.  Alongside this risk are many others, including difficulties in determining the ultimate beneficial owner, anti-money laundering, terrorist finance controls, economic sanctions, as well as present and former government officials who may sit on corporate boards, or even in management.

Listen in as she explains the challenges of compliance, the risks in former Communist countries, and the role the EBRD is playing in fostering compliance and being a beacon of integrity.

By Adam Turteltaub

The European Bank for Reconstruction and Development (EBRD) was created after the fall of the Berlin Wall to help develop open and sustainable market economies in countries that were committed to and applying democrat principles.  To date, the EBRD has invested €130 billion in 5200.  Its focus is on private sector investment and supporting six market transition qualities:  competitive, green, inclusive, well governed, resilient and integrated.

Lisa Rosen, the bank’s Chief Compliance Officer, along with her team play a central role in helping the EBRD succeed in its mission.  It’s not always easy, she explains in this podcast, since many of the countries where the bank has investments have serious corruption risks.  Alongside this risk are many others, including difficulties in determining the ultimate beneficial owner, anti-money laundering, terrorist finance controls, economic sanctions, as well as present and former government officials who may sit on corporate boards, or even in management.

Listen in as she explains the challenges of compliance, the risks in former Communist countries, and the role the EBRD is playing in fostering compliance and being a beacon of integrity.

By Adam Turteltaub

These days everything is online, well, most everything.  As Kristy Grant-Hart of Spark Compliance Consulting discovered, compliance program information is often the exception.  It may not be there at all, or not be as optimized as it should be.  For example, one third of the Codes of Conduct available on sites surveyed weren’t even in color.

When she sat down with us at the Berlin European Compliance and Ethics Institute she advised compliance professionals not to think of the website as just the website.  Instead, ask:  What does the website say about the compliance program?  Is it painting the right picture of your program?  Do you have the disclosures necessary under the UK and California human trafficking and modern slavery laws?  Is the code of conduct up?  Is there a CEO letter?

Your employees, venture capital firms, and even prospective employees may be looking.

Also looking at the site are individuals who want to raise a potential issue.  These people may work at your organization or for a vendor or supplier.  If it’s difficult for them to find the helpline info, they may keep silent or raise their issues elsewhere.

Listen in to learn more about how your compliance program can raise its web game

By Adam Turteltaub

These days everything is online, well, most everything.  As Kristy Grant-Hart of Spark Compliance Consulting discovered, compliance program information is often the exception.  It may not be there at all, or not be as optimized as it should be.  For example, one third of the Codes of Conduct available on sites surveyed weren’t even in color.

When she sat down with us at the Berlin European Compliance and Ethics Institute she advised compliance professionals not to think of the website as just the website.  Instead, ask:  What does the website say about the compliance program?  Is it painting the right picture of your program?  Do you have the disclosures necessary under the UK and California human trafficking and modern slavery laws?  Is the code of conduct up?  Is there a CEO letter?

Your employees, venture capital firms, and even prospective employees may be looking.

Also looking at the site are individuals who want to raise a potential issue.  These people may work at your organization or for a vendor or supplier.  If it’s difficult for them to find the helpline info, they may keep silent or raise their issues elsewhere.

Listen in to learn more about how your compliance program can raise its web game

By Adam Turteltaub

Going from good to great has a different meaning to all of us, but generally, it means moving the compliance program up from informal to evolving to optimized.  Along the way, there are a number of barriers to evolution, including potentially hundreds of offices around the world to reach,  where compliance sits in the organization, resource constraints, and culture.

The key to going from good to great is to move away from just being a compliance program manager into part of the business decision-making process, explains Jacki Cheslow, Director-Business Ethics and Compliance, Avis Budget Group.  In this podcast, recorded at the 2019 European Compliance and Ethics Institute, she explains that making yourself valuable from a business perspective makes all the difference.  Some of the other pieces of advice she offers:

* Changing the conversation from “no you can’t” to “yes you can” but with the explanation of what’s required

* Focusing on the “what’s in it for me” for your audience

* Using data analytics to demonstrate progress

* Leveraging your contacts across the organization to be a connector when business people have challenges

Listen in for more good advice on being great.

By Adam Turteltaub

Going from good to great has a different meaning to all of us, but generally, it means moving the compliance program up from informal to evolving to optimized.  Along the way, there are a number of barriers to evolution, including potentially hundreds of offices around the world to reach,  where compliance sits in the organization, resource constraints, and culture.

The key to going from good to great is to move away from just being a compliance program manager into part of the business decision-making process, explains Jacki Cheslow, Director-Business Ethics and Compliance, Avis Budget Group.  In this podcast, recorded at the 2019 European Compliance and Ethics Institute, she explains that making yourself valuable from a business perspective makes all the difference.  Some of the other pieces of advice she offers:

* Changing the conversation from “no you can’t” to “yes you can” but with the explanation of what’s required

* Focusing on the “what’s in it for me” for your audience

* Using data analytics to demonstrate progress

* Leveraging your contacts across the organization to be a connector when business people have challenges

Listen in for more good advice on being great.

By Adam Turteltaub

While Romania is a part of the European Union (EU), it has a corruption problem typical of less-developed states.  Admitted to the EU under a Cooperation and Verification Mechanism, it is subject to monitoring, according to Charles Vernon, an attorney in Bucharest with a large compliance practice.

Lately, the country has not fared well with its EU monitors who have added eight additional steps for the country to take.

The reason for the remedial action is what Charles describes as steps backward when it comes to fighting corruption.  The leadership has tried to loosen anticorruption laws and constitutional courts have stepped in, overturning verdicts on narrow technical grounds, he reports.

At the same time, however, the public has not been quiet, taking to the streets in protest.  In addition, the younger generation recognizes the need for better governance nationally and looks to multinational companies as places where they can work with integrity and rise on their own merits.

Listen in as Charles explains the risks of doing business in the country, the need for greater vetting of suppliers, and what’s going on in privacy laws.  GDPR is not as well implemented as elsewhere in Europe, but it is still a force to be reckoned with, and privacy is already closely monitored in the healthcare industry.

By Adam Turteltaub

While Romania is a part of the European Union (EU), it has a corruption problem typical of less-developed states.  Admitted to the EU under a Cooperation and Verification Mechanism, it is subject to monitoring, according to Charles Vernon, an attorney in Bucharest with a large compliance practice.

Lately, the country has not fared well with its EU monitors who have added eight additional steps for the country to take.

The reason for the remedial action is what Charles describes as steps backward when it comes to fighting corruption.  The leadership has tried to loosen anticorruption laws and constitutional courts have stepped in, overturning verdicts on narrow technical grounds, he reports.

At the same time, however, the public has not been quiet, taking to the streets in protest.  In addition, the younger generation recognizes the need for better governance nationally and looks to multinational companies as places where they can work with integrity and rise on their own merits.

Listen in as Charles explains the risks of doing business in the country, the need for greater vetting of suppliers, and what’s going on in privacy laws.  GDPR is not as well implemented as elsewhere in Europe, but it is still a force to be reckoned with, and privacy is already closely monitored in the healthcare industry.

By Adam Turteltaub

One of the most provocatively titled sessions at the 2019 SCCE European Compliance and Ethics Institute was “Becoming ‘Invited In’:  Creating Compliance ‘Addicts’ Globally.”

Aversion, not addiction, is more typically associated with compliance, unfortunately, and it made me want to learn more.  So, I asked the two co-presenters to sit down for a podcast to share what they meant by the term.  Nadege Rochel, Global Compliance Manager and Susan Roberts, Chief Compliance Officer of Hollister Incorporated both readily agreed.

A compliance addict, they explained, is someone who does something extra beyond simple compliance.  So, how do you get people to become addicts?  Not surprisingly by rewarding them.  But what may be surprising is how simple a reward it was:  a pin.  It turned out to be both an offer of recognition and a way for the recipient to be recognized by his or her peers as someone with a strong commitment to ethics and compliance.  It also triggered a competitive streak, with others wanting to earn the pin as well.

This simple approach has infused their compliance programs and offers lessons for others seeking to create cultures in which the compliance program is embraced.  As they explain, they did not stop with pins.

At sales meetings they try to schedule lunches and breakfasts with people, and even join in at the end of the day.  There’s a compliance booth where employees can win a ribbon or candy for answering a question correctly.  And, once again, those who wear the ribbon generate interest in those who have not yet earned one.

These techniques, coupled with several other business-team friendly initiatives, have helped the compliance team and program make tremendous strides.

Listen in, even though we can’t give you a pin for doing so.

Note:  Nadege speaks first.