CEOs may set the ethical tone from the top, but they need a supporting capable 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 // TELL US WHAT YOUR GROUP IS FOCUSED ON THESE DAYS.
(We’re focused on) ensuring that we stay on the leading edge of ethics and compliance issues. Two big issues we are grappling with: 1) Confidential, sensitive, portable data on PCs and laptops; and 2) Investigation procedures and techniques.
02 // ARE THERE ANY PARTICULAR INITIATIVES THAT YOU HAVE FOUND WORKED WELL AND YOU WILL SHARE WITH OTHERS?
Conversation and buy-in are great enablers. Whether working with a European Works Council, Human Resources, Security, Legal or general employees, I start by talking about the issue or initiative upfront, soliciting their thoughts and suggestions. Then I incorporate what I can without undermining the mission or objective of what I must accomplish.
03 // WHAT IN YOUR BACKGROUND HAS MOST PREPARED YOU FOR THIS POSITION?
(Previously) I worked in accounting, auditing and finance jobs. I believe I earned a reputation for asking the tough questions and expecting some answers or action. In the field of ethics and compliance we are not so much creating new ground to thought, but enabling our organizations to face up to tough questions before they become big problems.
04 // WHAT KEEPS YOU UP AT NIGHT?
We conduct ongoing internal surveys relative to our ethical culture; one of the questions asks if you would contact the Ethics Office if you observed unethical conduct. The number of people who say they would not contact us is three times larger than the numbers who say they have observed unethical conduct. That bothers me!
05 // IS THERE ONE SPECIFIC PIECE OF ADVICE THAT YOU COULD SHARE THAT YOU WISHED YOU HAD KNOWN WHEN YOU FIRST GOT THE JOB?
Develop a thick skin! To do your job right often means you’re not going to score very high in popularity contests. Hopefully, over time your management and employees develop respect for the tough role that you play.
06 // WHO DO YOU REPORT TO? WHAT ROLE HAVE THEY PLAYED IN THE COMPLIANCE AND ETHICS PROGRAM?
Our Ethics Office reports directly to the CEO with unrestricted access to the Audit Committee of the Board of Directors. Our CEO, Anne Mulcahy, is a relentless champion of “doing the right thing” for the company. Likewise, our Audit Committee is fully engaged. They review our annual plan, make suggestions, and take ownership for the oversight of our activities.
07 // WHAT’S THE WORST JOB THAT YOU HAVE EVER HELD AND WHY?
I worked for one of the Big 8 (pre-downsizing) accounting firms in Harrisburg, PA. I was assigned to an audit of a city program that received federal funding to conduct a compliance audit. The audit manager directed me to literally “walkthrough” a typical day with one of the employees and document the procedures to support our write-up on undocumented procedures. We always wore three-piece suits back then. And our client was the city’s rat control program. I spent hours climbing through condemned buildings in the worst parts of town!
08 // WHAT IS THE MOST SATISFYING ASPECT OF YOUR CURRENT JOB?
Most employees want to come to work, do a good job, do right by the company and receive a fair wage. In this job, we have the means and resources to enable inequitable, dishonest, or just plain wrong situations to be raised, addressed and resolved. It makes the workplace a better environment for those who want to do a good job and do right by the company.
