Anti-Corruption Fight Goes Global

See-No-Evil

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Law enforcement agencies around the globe are increasing their cooperation in investigating and prosecuting corruption cases, and a panel of chief compliance officers said Tuesday that is a good thing for companies who want to play by the rules.

Speaking at an anti-corruption conference in New York, Al Rosa, chief compliance director and senior executive counsel for General Electric, said the increased cooperation among law enforcement is good for a company like GE, which operates in 165 countries. “We want to be on a common standard” for compliance that all our employees can adhere to, he said. To help foster the right compliance culture in each of those countries, Mr. Rosa said GE works to hire senior compliance talent from that country. This ensures that employees will be told about compliance in a way they can understand, especially when using local examples of compliance successes and failures. “Good and effective compliance is local compliance,” he said. “Local investment is the key to our compliance program.” Ashley Watson, chief ethics and compliance officer at Merck, said the increased enforcement cooperation especially helps the company push its anti-corruption message in countries “where culturally the [Foreign Corrupt Practices Act] doesn’t make sense.” In these places—where gift-giving is seen as a cultural norm and expectation–local enforcement of anti-bribery laws “makes our job easier.”

Nancy Higgins, chief ethics and compliance officer at Bechtel, said most companies have the same goal as the governments—to weed out corruption. “We don’t want a situation where there is an uneven playing field,” she said. “The more active other countries are, the better it is for all of us.” A key part of making compliance more accessible to a worldwide set of employees is to simplify the message and make it easy for people to digest, said Mr. Rosa. To that end, he said GE streamlined its code of conduct, cutting the 65-page document by two-thirds, and then also creating a two-page version. Both actions increased employee engagement with the code, and more buy-in from senior leadership. “Employees started to read it,” he said. Ms. Watson said by simplifying the compliance message, compliance officers can “hone in on the why and not the what” of the policies and procedures employees are being asked to adhere to. “To succeed globally you need employees to understand the why,” she said. “We need our employees exercising good judgment and not just to simply follow the rules.” Ms Higgins said Bechtel works to instill its values and the idea of acting with integrity into its code and into all employee messaging and training. “Tying into our values is very important to us,” she said. “We can’t write rules to cover every situation but everyone can understand what the right thing to do is.” To foster that culture of open communication, Mr. Rosa said he spends about one-third of his time encouraging employees to report any concerns they have. Analyzing data GE found about 8% of the time people used the company hotline to report a concern, while about 90% went to their manager.

So the company created a system for managers to report concerns, and this has increased the number of incidents being brought to the company’s attention. Having engaged employees who are willing to report issues “is the best way to detect issues early,” he said.