The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Katie Smith who is the Vice President for Ethics at Assurance. She previously served as Assistant Vice President and Chief Ethics Officer for USAA and Executive Vice President and Chief Compliance and Ethics Officer at Convercent.
Katie is passionate about compliance, having worked in the field for 20 years, building high-performing teams and increasing employee engagement by up to 300%. She has proven expertise in building and promoting talent, creating a trust-based culture, anti-corruption, code of conduct, conflict of interest, marketing internal programs, training and awareness, investigation excellence, data privacy and process efficiency. She is a much sought after public speaker and contributor featured in Wall Street Journal, Time, Fortune, NBC and Compliance Week. Katie’s commitment to the compliance profession is well as she currently sits on the Board of Directors of the Ethics and Compliance Initiative (ECI).
In this first episode, we consider Katie’s journey to the CCO role. She talks about how her Liberal Arts degree, not a JD, facilitated her success in compliance. She details her initial corporate work in HR and moving over to the compliance field and her journey to the CCO chair.
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Tom Fox welcomes Andrea Bonime-Blanc to this week’s show. Andrea is the author of Gloom to Boom: How Leaders Transform Risk into Resilience and Value, and a foremost name in compliance. She recently joined the Board of Advisors of Crisp. Andrea and Tom talk about her new role, and the increasing importance of ESG.
Risk Intelligence as a Service
Andrea explains that Crisp provides risk intelligence as a service: their “series of algorithms search the open Internet and the dark web and a variety of other sources for potential risks affecting their clients,” she says. “It’s basically a way of giving an early warning system to the client on risks that may affect the brand.” She adds that having a transversal approach towards emerging risk is vital.
Compliance Should Be On Every Board
Tom comments that Andrea has written extensively about the need to have compliance professionals in the boardroom. She responds that it’s even more critical today: “Risks are an everyday occurrence, and we have a convergence of big strategic risks this year like we’ve never seen before…” A compliance professional brings a unique perspective regarding risk, regulatory and compliance issues that helps to create a holistic long term strategy for an organization, especially in today’s complex, interconnected world.
The Importance of Inclusion
Andrea and Tom discuss why inclusion may be even more important than diversity. “I think people are starting to realize there’s some root causes here that need to change,” Andrea remarks. “And they’re realizing that these are things that need to happen within their organizations in order to not just make their organizations reflect society more than they have, but to actually create competitive advantage. And that’s really the bright side of this whole thing is, you’re not just doing it to be a good citizen, you’re doing it because it’s good business as well.”
Moving Towards Coordinated ESG
Environmental, social, governance and technology issues are non-financial but can have a major financial and reputational impact on any organization, Andrea comments. As such, they need to be handled strategically to bring the most benefit to the company. The good news is that if you manage these issues well, you create better products and services. “Value is always the other side of the coin of risk,” Andrea comments.
Resourcs
GEC Risk Advisory
CrispThinking.com
Gloom to Boom: How Leaders Transform Risk into Resilience and Value
Have you ever thought of compliance as an ecosystem? When you consider the concept, it becomes clear that this is one thing every company should strive towards. Obviously, every multi-national company must have a compliance program. But to have true effectiveness, your compliance program must be operationalized throughout the organization. One way to facilitate this is through the ecosystem concept.
There is another way that this ecosystem approach can make your compliance program more effective. Think about the third parties your company has both on the sales and the supply chain side. If you could work to create a closer ecosystem with those stakeholders from the compliance perspective, it would not only make the business relationship stronger but also make the entire business process more efficient.
2020 has brought a paradigm shift to corporate compliance as a result of technological and digital innovation. CCOs who cannot interpret the data from their own systems will likely find themselves consigned to the dustbin of corporate luddites. Compliance will be moving into a new era of collaboration and connection to more fully operationalize compliance to make all business stakeholders more efficient and at the end of the day more profitable.
Three key takeaways:
- A compliance function’s customers are a variety of stakeholders.
- Compliance can improve business processes.
- A compliance ecosystem can help to operationalize compliance.
Welcome to a special five-part podcast series, The Six Elements of an Effective Compliance Program. This podcast series is sponsored by StoneTurn. To celebrate Corporate Compliance and Ethics Week, we will consider each of the six elements required for an effective compliance program. They include: Risk Assessment, Governance and Structure, Policies Procedures and Controls, Training and Education, Oversight and Reporting, and Response and Enhancements. Over this five-part podcast series, I will be joined by Stephen Martin and Valerie Charles, Partners and StoneTurn and Toby Ralston and Jamen Tyler, Managing Directors at StoneTurn.
In this first episode, I visit with Stephen Martin on Risk Assessments. Highlights include:
- Properly seen, an effective compliance program is an ongoing ecosystem. Why is an effective compliance program dynamic, requiring an ongoing, multi-disciplinary approach?
- Businesses have traditionally had an historical bias toward financial and operational risk. Why have about legal and regulatory and reputational risks become so much more important in the era of Covid-19 and social justice movements around Black Lives Matter and Diversity and Inclusion? Why must these risks be assessed?
- The Department of Justice mandated in its 2020 Update to the Evaluation of Corporate Compliance Programs that risk assessments be performed on a much more ongoing basis, such as when risks change. What does this mean in practice?
- The Department of Justice said in its 2020 Update that compliance must break down silos and functional impediments to an effective compliance program. Why do you see this as so critical?
- The 2020 Update mandated greater information from a compliance program be used to improve it. How do you leverage code and policy questions received into enhancements to an overall Enterprise Risk Management process?
Resources
For more information on StoneTurn, click here.
In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for April 2020.
Some of the highlights include:
- DOJ Announces Repatriation of $300 Million to Malaysia in Connection With 1MDB.
- Colombia Officially Enters the OECD. What was the process and what does this mean for Colombia?
- What is the DOJ saying around FCPA enforcement in the Covid-19 era?
- London court discharges 3rd ever unexplained wealth order?
- ENI resolves Algeria FCPA allegations.
Resources
To a copy of the Top 10 International Anti-Corruption Developments for April 2020 Newsletter click here.
In today’s edition of Sunday Book Review:
- The Mysterious Affair at Styles
- Murder on the Orient Express
- The ABC Murders by Karen Valentine
- Peril at End House
- Murder at the Vicarage
For additional reading see The Essential Agatha Christie
Thinking you should take it easy on your employees – maybe even yourself – during this crazy pandemic season of work-life?
Pump the brakes on that thought for a second!
While they may seem daunting to perform or stressful to receive, ultimately performance evaluations done right will help relieve stress for both parties AND maintain – even improve – performance.
We know that oftentimes when times get tough, business gets lean for most companies. However, regardless of what difficult cuts leaders (maybe you are the leader) have had to make during this pandemic season of work-life, one thing is for sure – performance evaluations must be kept, not cut. In today’s episode, let’s talk about why!
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