To leave a legacy of operational excellence in compliance is what Global Chief Compliance Officer, Strategic Leader, and Partner at StoneTurn Jonathon Kellerman hopes to achieve in this dynamic industry.
He has been at the forefront of the evolution of compliance programs in health care, life sciences, and pharmaceuticals with over 25 years of experience in compliance strategy, program development and execution; controls design; operational excellence; risk assessment and mitigation; complex investigations; and negotiating and managing government settlements.
Major takeaways discussed in the episode:
✔️ Glean lessons from Jonathon’s unique journey starting a health care compliance practice that served as the first in the industry. His experience in a consulting practice helped health care providers with complex compliance challenges.
✔️ Traditional compliance has been limited by the rigid standards around an audit mentality. Jonathon shares that the focus on looking at transactions in silos instead of the holistic approach of looking at data over time is what’s made compliance programs from being truly effective.
✔️ Compliance programs limiting themselves to the standard practice of risk management will risk being irrelevant in future companies.
✔️ The COVID-19 pandemic broke barriers and accelerated digital transformation. Every company does it to some extent in utilizing digital platforms and data that opens up new ways of rethinking our traditional engagements.
✔️ Advanced technologies use data and digital platforms that create a new type of risk. But it also means that more than ever, there’s a lot of pressure put on companies to operate quickly and very efficiently.
✔️ The skills needed for the compliance professionals of the future is something never taught in law school. Jonathon emphasizes that an individual in the compliance space must speak business language, have trust and credibility, and be willing to think outside the box.
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Jonathon L. Kellerman is a Partner with StoneTurn, brings over 25 years of experience in compliance strategy, program development, and execution; controls design; operational excellence; risk assessment and mitigation; complex investigations; and negotiating and managing government settlements.
A former Global Chief Compliance Officer in the heavily regulated pharmaceuticals industry, Jonathon draws on his in-house career, as well as 20 years as a trusted adviser, to counsel executives and Board members on evolving compliance risk and to help clients design innovative, data-enabled, and business-friendly compliance solutions to proactively and reactively manage risk.
Jonathon has deep experience pioneering technology and data-driven compliance solution innovation, operational improvement, and business protection/enablement in the pharmaceutical, life sciences, and healthcare industries, including his prior role as Global Chief Compliance Officer of Allergan.
LinkedIn: https://www.linkedin.com/in/jonathonkellerman/
Email: jkellerman@stoneturn.com
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About Thomas Fox:
Thomas Fox, the Compliance Evangelist®, is one of the leading writers, thinkers, and commentators on anti-bribery and anti-corruption compliance. In this latest edition of The Compliance Handbook, he continues to arm seasoned compliance professionals and those new to the realm with the practical, actionable guidance and tools needed to design, create, implement and continually enhance a best practices compliance program.
Order your copy OR copies of The Compliance Handbook: A Guide to Operationalizing Your Compliance Program.
http://www.lexisnexis.com/fox25
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YOU are at the center of The Ethics Movement—the journey to move ethics to the center of business, and build a better world in the process. Join hosts Tom Fox and Philip Winterburn as they unpack the big ideas of ethics and compliance, in the context of today’s big news stories—on The Ethics Movement. As we return to the office setting, ethics and compliance teams have a unique opportunity to reinvent the way we communicate with employees. Ronnie Feldman, founder of Learnings & Entertainments, pitches humor, storytelling, and improv as a new source of inspiration for compliance training.
Resources:
Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)
Learnings & Entertainments (Website)
60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.
Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.
Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.
Tales from the Hotline – check out some samples.
Tom Fox’s guest this week is Heather Buker. Heather is the Product Manager at Allgress and oversees the full life cycle of development and QA processes. She has spent her professional life in the world of computer engineering until making her way into the cybersecurity space. Tom welcomes her to this week’s show to talk about a new innovation from Allgress around authorizations to operate in the federal sector.
All About Allgress
Heather explains that Allgress is for highly regulated industries such as technology, government, and healthcare. “Allgress in general is a global provider of next generation audit, compliance, security and risk management solutions for organizations and their business partners to meet business risk objectives,” she says. Allgress enables organizations to streamline these processes and manage assessment monitoring in a more simplified way, and without the need for a contingent of consultants.
Fed Ramps & ATOs
Tom asks Heather to explain what fed ramps and ATOs are and why they’re important. Fed ramps are federal risk and management programs that are government wide. The programs provide a standardized approach to security assessments and continuous monitoring for cloud-based services. An ATO is the government giving you the authorization to operate a compliant cloud-based service. ATOs and fed ramps are necessary if you sell your service to the federal government. After acquiring your fed ramp or ATO, then you can focus on maintaining the continuous monitoring that the ATO provides.
How Allgress Maintains Your Federal ATO Effectively
“We’re going to give you the dynamic preparedness assessment; we’re going to automatically determine your impact level based on a survey; we’re going to guide you through [attaining an ATO] step by step,” Heather tells Tom. Allgress completely streamlines this process via automation and creates the audit trail that its clients need. “When the auditors come and they have questions, you’re gonna have all of the answers, and it’s going to be in the single pane of glass view that Allgress provides,” she adds. Allgress provides all the evidence and policies necessary for when you’re testing to the federal controls.
The Impact of COVID-19 & What’s Next
The pandemic put a spotlight on the need for GRC solutions and exposed those companies that didn’t have those processes in place. It was a reminder to organizations that we never know when unexpected risk may strike, how we may be impacted, and how it may affect our organizational systems. Businesses have to start preparing for unexpected risks within our organizations. Heather explains to Tom that Allgress helps with this by automating organizational and partner risk assessment and leading them in the direction of a recovery plan. Businesses also need to be putting more importance on the usability of their products.
“User adoption is something that’s so difficult to achieve when you introduce a new product to your workforce… It’s imperative that GRC solutions continue to become more user-friendly and reduce that learning curve so that users are going to adopt the technology more quickly and with ease,” Heather remarks.
Resources
Heather Buker | LinkedIn | Twitter
In today’s edition of Daily Compliance News:
- Q&A with Erin Kelly. (WSJ)
- Is this SFO still relevant? (Financial News)
- US blocks Aon-Willis Towers merger. (FT)
- SEC fighting discrimination. (Houston Chronicle)
In this episode, the Kitchen looks at EU issues Forced Labor Due Diligence Guidance for supply chains and the Kitchen takes a closer look at this latest advisory in the area of modern slavery detection and prevention.
Gwen Hassan has been championing the fight against human trafficking for quite some time. The heartwrenching story of a young girl in SouthEast Asia brought the issue to her attention, but realizing that human trafficking is also a local issue spurred her to take action. “And since that time,” Tom Fox commends her, “you have been one of the leaders to talk about this issue in the context of either supply chain and overall corporate approach or compliance programs.” In this week’s show, Tom and Gwen discuss why fighting human trafficking is a compliance issue, and where it fits in ESG.
Part of Compliance
Human trafficking takes place everywhere, including in the US. Gwen tells Tom that there’s already an existing infrastructure with regard to third-party diligence, which could be used to fight human trafficking as well. She remarks, “…Why not start using that same set of controls and processes and power to make sure they’re doing their part to root out trafficking from their supply chain as well?” Her belief is that stamping out human trafficking should be part of every corporate compliance program. “The synergy with corporate compliance really came to the forefront with the UK Modern Slavery Act,” she points out.
Why US Companies Should Care
Why should fighting human trafficking be an issue for companies who don’t trade internationally, Tom asks Gwen. “One of the biggest, kind of, eye-openers for me was learning about the extent of trafficking that’s right here in the US,” she responds. Even if your company does not do business overseas, you could still be contracting with businesses that engage in or support human trafficking. It’s imperative that you do your due diligence about third parties and even their subcontractors.
S or G?
Tom sees fighting human trafficking falling under the S in ESG. Gwen agrees that it does relate to social justice issues in a broad sense. In her opinion, it also is a G: companies should practice good governance, which includes robust third-party diligence. “The process side and the diligence aspects of a sustainable ethics and compliance program, fit very nicely with human trafficking… [and] the reasoning behind why you want to have a good program for human trafficking prevention relates back to social justice and the fair treatment of everyone who’s in your organization,” she remarks. Most business leaders immediately understand the reputational risk human trafficking poses to their companies. “Once you educate people as to the extent of the problem – the fact that it impacts everyone – it really makes a difference in their openness and their willingness to then invest,” she tells Tom. Government actions are helping the fight: once leaders know that there could be enforcement actions against them, they’re more willing to listen.
Resources
Gwen Hassan on LinkedIn | Email
In this Episode of the FCPA Compliance Report, I visit with three lawyers from Miller & Chevalier to discuss the Summer 2021 Edition. I am joined by Lauren Briggerman, Katherine Pappas and Ian Herbert. We take a deep dive into key areas of white collar enforcement and issues that every compliance, legal and business executive should be aware of going forward into the second half of 2021. Some of the highlights include:
Lauren Briggerman
- What are some of the significant developments in cartel investigations and prosecutions involving senior execs?
- What have you seen around wage-fixing and price fixing?
- Yet more prosecutions in the poultry industry. Why have we seen so many over the past few years?
- Anything new on the extradition front?
- We saw additional charges and a settlement regarding auto emissions testing fraud. Where do you see this issue internationally?
Katherine Pappas
- What has been the impact of the pandemic on white collar prosecutions?
- Where are we on government efforts to combat PPP and PPE fraud?
- Anything happening on the FCPA front with individuals?
- Do you expect to see a pickup on the corp FCPA front in the remainder of 2021?
- What does the Biden administration’s memorandum on corruption as a national security issue mean for corporations and executives?
Ian Herbert
- What did we see regarding individual prosecutions on the AML front?
- What about prosecutions for failures to set up AML compliance programs?
- What’s happening in crypto?
- Significant sentencings.
Resources
Miller & Chevalier
Lauren Briggerman
Katherine Pappas
Ian Herbert
Executive at Risk Newsletter, Summer 2021
In today’s edition of Daily Compliance News:
- Credit Suisse reaches settlement with former CEO. (WSJ)
- FTC asks for extension. (NYT)
- Hosting Olympics a very bad deal. (NYT)
- FinCEN whistleblower headed to jail. (Richmond Times)
In today’s edition of Sunday Book Review:
- Leviathan Wakes by James Corey
- Dark Matter by Blake Crouch
- The Moon is a Harsh Mistress by Robert Heinlein
- Do Androids Dream of Electric Sleep by Phillip Dick