Culture is one of those topics in ethics and compliance that everyone talks about—but it’s also one of the hardest things to define and even harder to build. At Compliance Week, Lisa Fine discussed this with Amy Schuh, partner at Morgan Lewis; Kilby McFadden, Managing Director and Head of Investigations at KPMG; and Michael Ortwein, Chief Compliance Officer and Assistant General Counsel at GM. Today, Amy and Kilby continue the discussion with Lisa Fine and Sarah Hadden.

They start by discussing what they see as a strong compliance culture. As Kilby says, it’s what happens when no one is watching. The conversation focuses on how organizations move beyond policies and training to build trust, encourage employees to speak up, and empower leaders to make ethical decisions—even when those decisions are difficult.

Amy and Kilby share practical insights from years of experience leading investigations and advising organizations, discussing who really owns culture, how companies can create trust in the reporting process, and why relationships with the business matter just as much as policies and procedures. They also explore the challenges of building a consistent culture across global organizations and offer ideas for strengthening culture even when resources are limited.

They also include key takeaways for compliance professionals, such as the importance of listening, staying curious about the business, and building relationships before issues arise, and each shares one “myth” about Ethics & Compliance they think should be debunked.