Natalia Shehadeh is a well-known compliance expert who worked in the energy sector for over a decade. She is now the Chief Integrity Officer at ABB, a multinational corporation in the robotics and process automation space. Natalia believes that using data and technology in compliance is no longer an option: “It is absolutely mission-critical to the proper functioning and success of our function and our mission,” she tells Tom Fox and Valerie Charles. In this week’s show, Natalia chats with Tom and Valerie about the importance of leading with data, including how to use data to measure cultural buy-in.
Building Culture with Data
“We are trying to look at opportunistically, how to leverage data for purposes of giving us real-time insights on the health of our integrity culture in the company; how to do so effectively and efficiently, and with a real keen eye towards innovation,” Natalia remarks. Her cross-functional team – which includes data professionals and business analytics experts – is a major reason they have been so successful in moving towards that goal, she says. Their focus is not only on monitoring from a risk perspective, but also measuring how effective their communications for learning purposes are. Valerie asks her about the data sets they use. She explains that they monitor internal social media posts as well as their learning assets to measure sentiment. “A lot of data we’re looking at and trying to get a feel for, Are we communicating effectively in the eyes of our employees? And how do we think that’s moving the culture needle?” she tells Valerie.
Getting Cultural Buy-In
“Data analytics or tech solutions on their own aren’t particularly useful without the cultural buy-in of the organization,” Valerie comments. She asks Natalia how she gets buy-in at ABB. Natalia responds that ABB is a data-focused organization, so they understand the importance of using data. However, she advises, it takes “care and feeding culturally” to get to the point where you have quality data sets that can provide rich insights.
Facilitating Learning Through Data
ABB is focused on “communicating learning in an effective way”, Natalia tells Tom and Valerie. To this end, they revamped their approach to employee training, focusing instead on a data-driven stratified approach. Traditional compliance and integrity training is no longer mandatory; instead, employees interact with learning assets as and when they need, similar to how they use Youtube to find a quick solution to a problem. “We really believe in inculcating an adult self-learning objective,” Natalia says. “…The concept is [to] create a simple learning approach where people will want to come back for more because it’s easy, it answered the question that they had, and hopefully we can make it a little bit fun.”
Resources
Natalia Shehadeh on LinkedIn
ABB
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Affiliated Monitors Managing Director Don Stern hosts an engaging conversation with the Former Deputy Attorney General, King & Spalding’s Rod Rosenstein, and Affiliated Monitors Managing Director Eric Feldman as they conclude a two-part podcast on “The Past, Present, & Future of Compliance and Independent Monitoring.”
In part two, the trio shifts their focus to independent monitoring. People have some misconceptions about monitoring. Most companies don’t particularly welcome having a monitor. They view it as intrusive. They view it as — in some cases — unnecessary.
Historically, prosecutors (including the Department of Justice) are not necessarily focused on what happens after there’s a conviction. You get the result; you move on to the next investigation. What happens to the company? Does it really get the message, and has it made changes? Have prosecutors become more focused on what happens after the conviction, and if so, why?
The first question is: how do you determine whether there’s a need for a monitor? And that really focuses on the issue that has been identified, which is that the purpose shouldn’t be punitive. The monitor is not intended to be a form of punishment. It’s supposed to be prospective.
The second question is: what is the scope of responsibilities of the monitor? A company may have made a mistake in one area. Do we give them monitor authority over that area alone, or do we broaden the authority of the monitor?
As is our “Integrity Through Compliance” tradition, Rod and Eric share their key takeaways on monitoring:
Eric:
- First off, avoid a monitor. It may seem funny for a monitor to say avoid a monitor, but knowing that a company can demonstrate that it has strengthened its compliance program and its corporate culture, there is an opportunity to avoid a monitorship, given the right proactive measures are taken.
- If you do have to have a monitor, make lemonade from the lemons. In fact, one of our clients has deemed out monitorship “Project Lemonade.” Companies should take advantage of it, and use the monitor as an opportunity to get focus and resources on compliance within their company.
Rod:
- Rod picked up on Eric’s first point to avoid a monitor. The goal of the latest DOJ policy is to drive constructive change. Companies can avoid a monitor — even after wrongdoing occurs — by changing corporate leadership and culture, by improving internal controls and compliance programs.
- Demonstrate that your program will deter future misconduct. This can be accomplished proactively before a company gets in trouble (or even after a company gets in trouble), so they’ll be best positioned to make their pitch to the department about the ultimate resolution.