Senior Manager & Ethics Office — Cisco Systems Inc.

What is your group focused on?
What makes the compliance program at your company unique?
To which group do you report? What role does this organization play in your ethics and compliance program?
What keeps you up at night?
What’s the single best piece of advice you would give to someone who is new to this position?
How do you handle global issues in compliance and ethics – how does it different from country to country in which you operate?
What do you think is “next” in terms of compliance and ethics programs for corporations?

What is your group focused on?

The Ethics Office is responsible for authoring, maintaining and enforcing Cisco’s Code of Business Conduct and related policies. We are also responsible for educating our employees on such policies. We aim to further enhance the ethical culture here at Cisco. To make this happen our focus is two pronged: 1. We “proactively” author policies, create and provide education, and communicate with our employees to ensure they understand such policies as well as the ethical expectations of Cisco employees. 2. We respond to questions and concerns pertaining to our Code and work in conjunction with our investigative team to address matters requiring additional attention.
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What makes the compliance program at your company unique?

I believe that our cross functional approach to most everything we do sets us apart from other company’s Compliance programs. The Cisco Ethics Office works collaboratively with all of our partnering organizations to share resources, leverage initiatives, and enhance our program offerings. Such collaboration not only creates a more unified look and feel from a users standpoint, but it enables us to function as a unified team no matter where we are in the world or which organization we report into.

Corporate Secretary Magazine recently presented Cisco with the award for Best Overall Ethics, Compliance and Governance Program for 2009. The judges said the following about our collaborative successes here at Cisco: “Cross-functional working groups collaborate to monitor compliance and governance throughout the diverse geographic regions in which the company operates. Cisco has achieved the holy grail by elevating compliance and governance beyond a mandatory regulatory consideration and making it a true function of the overall business. The company has fully integrated governance into all aspects of the business, including operational and profit centers, making it an integral and indistinguishable part of the corporate fiber.

Governance is further enhanced by actively including all stakeholders and works to advance overall standards within the sector and the wider business community.”
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To which group do you report? What role does this organization play in your ethics and compliance program?

I report into an organization called Governance, Risk and Controls Group (GRC). GRC retains responsibility for the greater Ethics, Investigations, Audit and Risk Management functions of the company. With a hard reporting line into the Audit Committee of the Board of Directors and a dotted reporting line into the Finance function, we are able to aggressively pursue our charters with the independence required to do our jobs effectively. Through its various compliance functions, GRC is able to keep its finger on the “Pulse” of the company’s ethics and internal controls.
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What keeps you up at night?

Knowing that no matter what lengths you have gone to in order to implement an effective Code of Conduct and internal controls, the misconduct of just one employee can significantly affect your reputation and cause the organization damage. This is one of the reasons we utilize so many unique communication mechanisms (such as: websites, wikis, discussion forums, cartoons, creative videos, surveys, certifications, training modules, posters, direct emails, senior leader messaging, broadcast voice messaging, video conferences, news articles, manager portals etc.) in an effort to reach each and every employee in a manner that resonates well with them.
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What’s the single best piece of advice you would give to someone who is new to this position?

Don’t go it alone. Recognize that you have partnering organizations within your company with similar goals and objectives which are likely ready and willing to share their resources and ideas. Doing things together is much easier and forges strong relationships for the future. Also, reach out to the Ethics and Compliance community. It is a network of fantastic people who are willing to share experiences and ideas.
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How do you handle global issues in compliance and ethics – how does it different from country to country in which you operate?

We have written our Code of Business Conduct so that it is globally applicable and culturally sensitive to the many countries in which we do business. That said, as anyone who has been immersed in ethics and compliance management for a while can tell you, you must intimately understand the laws and cultural rules of each region as issue arises in order to achieve your desired result. Reaching out to local management, HR or legal counsel prior to addressing the concern is usually beneficial. Their experience of having lived in that particular local and dealing with local law and issues can often dictate a proper course of action to deal with the concern. We have a fantastic team of Ethics Investigators scattered around the globe to deal with issues “real time” as they arise. Most all of these investigators are native to the regions in which they work. Their collective knowledge and experience has proven invaluable when addressing concerns in even the most remote areas of the world in which we operate.
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What do you think is “next” in terms of compliance and ethics programs for corporations?

I think we are entering into the “technology” phase of ethics and compliance. Compliance and ethics professionals are constantly dealing with the issue of scalability. How do we scale, effectively manage a global program and communicate our messaging and training out to a global workforce in the tens or hundreds of thousands? By incorporating technology in most everything we do. Here at Cisco we are finding ways to leverage technology in everything we do. Such an approach not only helps us address the scalability problem, but it resonates well with our employees, who I would describe as very technologically savvy.
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