CEOs may set the ethical tone from the top, but they need a capable supporting cast to tend to the day-to-day implementation of the company’s compliance and ethics programs. What are these leaders on the front lines talking about and doing these days?

01 // WHAT IS YOUR GROUP FOCUSED ON THESE DAYS?
At GE we have a great tradition of integrity and compliance that’s been built by thousands of employees over more than a hundred years, but we also know that we are only as good as today’s performance. So, we have to continue our focus everyday on how we can keep our reputation. A critical part of that effort here at GE is our focus of bringing leaders in to lead integrity—not only legal and compliance teams, but senior company leaders to lead the program themselves. On a related note, we are also focusing on the challenges posed by the globalization of our businesses, and we are working on ways to make sure that as we expand geographically we maintain a focus on a strong and ethical culture. I think we are meeting that challenge, and that’s something that’s going to continue to be on the front burner.

We are also focusing on key areas in policy and legal risk. These include, for example, the Foreign Corrupt Practices Act, excellence in regulatory compliance, excellence in doing business with governments (both in the United States and overseas) and in a number of areas like that.

02 // WHAT SPECIFIC INITIATIVES HAVE WORKED WELL THAT YOU CAN SHARE WITH OTHERS?
We have found that process management like Six Sigma and related quality tools are critical to the successful operation of a strong compliance program. Strong process management allows our compliance teams to map critical operating processes and identify and examine the pieces of the process that we need to strengthen, monitor or build. So, for example, we’ve used the process management approach as a means of establishing a consistent, company-wide approach to regulatory compliance and excellence.

03 // WHAT PART OF YOUR BACKGROUND HAS MOST PREPARED YOU FOR THIS POSITION?
That would have to be my 20 years as a partner with litigation group Kirkland and Ellis. In that capacity I worked on numerous cases in the course of my career that arose directly from compliance lapses and, in many cases even more fundamentally, a failed compliance culture that allowed that lapse to happen. I saw firsthand what happens to good people, and honest people, who aren’t grounded in a strong culture of the sort that I’ve seen since I came to GE. My former position at Kirkland and Ellis, defending senior executives and others, also provided me with a unique insight into the human cost of compliance lapses, and how those lapses played out in terms of costing people their careers, their personal lives, as well as the company’s success and the company’s reputation for integrity. So, all of that work in the trenches really brought home to me the importance of having a compliance culture that helps people navigate the gray areas, which is where 99.9 percent of all the decisions that a leader has to make come from.

04 // WHAT PART OF YOUR JOB KEEPS YOU UP AT NIGHT?
Two words—unanticipated risk. At GE we’ve built strong processes and a disciplined approach to always try and look around corners and to proactively or, I even say preemptively, anticipate emerging legal, regulatory and political issues, threats and challenges to a company such as ours, especially as we’re expanding into more and more markets and we’re engaging with more and more regulators. But, however good I feel about the progress that we have made so far, you can never be good enough at this. You can never be good enough at detecting issues at an early stage and anticipating what types of concerns regulators, and the people working with regulators, are going to have two, three, four, or ten years from now. That’s what keeps me up.

05 // IS THERE ONE SPECIFIC PIECE OF ADVICE THAT YOU COULD SHARE THAT YOU WISHED YOU HAD KNOWN WHEN YOU FIRST GOT THE JOB?
Yes. From what I have seen so far, since joining GE, there is a tendency among a lot of companies to conflate the processes for establishing a strong culture and those for abating critical policy risks in a business. The main lesson that’s been brought home to me, and the main piece of advice that I would give to others, is that it is important to keep the processes for establishing the strong culture, and those for abating the critical risks in a business, both separate and distinct. Chief compliance officers really need to think of these and manage these separately in order to be successful in each area. The elements of a compliance program, what I’ll call the process element, for establishing a strong culture are so complicated and are so critical that if you don’t have a separate and distinct focus on making sure that you don’t do those right, they will get lost in the shuffle. I’m blessed to have experts in this area working with me at GE, and I really think that you need to have a team that is separately focused on the cultural issues and not the policy issues.

06 // TO WHOM DO YOU REPORT? WHAT ROLE HAVE THEY PLAYED IN THE COMPLIANCE AND ETHICS PROGRAM?
I report to our General Counsel, Brackett Denniston, and Brackett is intimately involved in virtually every aspect of the compliance work that I do. Brackett chairs what we call our Policy Compliance Review Board, which is the highest compliance review committee within the company. In that capacity he is both formally and informally involved in regular compliance operating reviews within each of our businesses. He is involved in establishing our company-wide integrity policies, and he works closely with me and others in terms of reviewing the compliance audit findings that we have, as well as issues that arise over the course of our compliance reviews. More fundamentally, there is a tradition at GE—started by Ben Heineman, who was Brackett’s predecessor, and then has been continued and expanded on by Brackett since he became general counsel—[of] having the lawyers fulfill a critical role of stewarding our integrity and maintaining our integrity and reputation at GE. Brackett and I both strongly believe that a strong compliance culture is an essential ingredient to a strong reputation and the type of integrity culture that we need in order to succeed in today’s world.

07 // WHAT’S THE WORST JOB THAT YOU HAVE EVER HELD?
That’s pretty easy. When I was in junior high school, I worked at the Dairy Queen in Urbana, Illinois for a summer and gained an extraordinary amount of weight. The food was free, and boy did I capitalize on it! At the end of the summer when I went with my mom to do my back-to-school shopping I discovered that wasn’t as good a fringe benefit as I thought it was. I’ve never been able to look at an ice cream cone the same way since, by the way, so maybe that is a therapeutic benefit of the job.

08 // WHAT’S THE DUMBEST/SMARTEST QUESTION THAT SOMEONE HAS EVER ASKED YOU IN AN INTERVIEW, AND HOW DID YOU ANSWER?
I think the smartest question that I have ever been asked during an interview was when someone asked me if I could spend 15 minutes talking with any historical figure, who would it be and what would I ask them. I said that I would want to meet with Thomas Jefferson. I would want to understand from him what it was about that remarkable group of men who met in Philadelphia that enabled them to navigate their strongly held differences and arrive at such a remarkable consensus. And the reason that I answered that is because I look at today’s political leaders, and I think that very, very few of them would have been able to make the type of contribution that virtually everyone who was in that Continental Congress made. So the root of my interest in talking to Thomas Jefferson, if I ever had the possibility, was to ask him what was it about that time that enabled us to have such an extraordinary group of leaders happen to convene in one place at just the right time for the history of our country.