
01 // WHAT IS YOUR GROUP FOCUSED ON RIGHT NOW?
Our big project this year is an extensive revision of our Code of Business Conduct. We significantly revised the Code in 2002, and the last five years of experience have taught us much about what works and what doesn’t. We are particularly focused on gathering as much feedback as possible from employees at all levels of the Company and from everywhere around the world. Five years ago, we did not have as many resources to devote to the effort, and we did not fully take into account all points of view. The ultimate decision on the content of the Code will rest with our General Counsel, Chief Financial Officer, and Ethics and Compliance Committee (with oversight from the Audit Committee of the Board), but it is important that the Code not just reflect a U.S.-centric corporate governance perspective. We are a global company.
02 // WHAT SPECIFIC INITIATIVES HAVE WORKED WELL THAT YOU CAN SHARE WITH OTHERS?
We post on our Ethics & Compliance intranet site a listing of recent Code of Business Conduct violations. We remove information that would identify the person or location, of course, but in each case explain what the employee did, why it violated the Code, and the resulting discipline. We also publish several of these in our quarterly newsletter. I believe these postings serve two purposes. First, they are an educational tool for employees to understand better the kinds of behavior that can get them, and the Company, in trouble. Second, they are an exercise in transparency. Employees can see how we treat certain conduct, and check us if they perceive any inconsistency or unfairness. It’s a small thing, but I think it sends a powerful message. It’s also the most visited page on our website.
03 // WHAT IN YOUR BACKGROUND HAS MOST PREPARED YOU FOR THIS POSITION?
As one who has multiple degrees and has changed career paths a couple of times, I believe that everything you do contributes to who you are and how you approach the next challenge. There is no question that as an attorney I bring certain skills and inclinations to the position that are different from someone who might have come from an audit or finance background, for example. In addition, I have also been a psychologist and an employment lawyer, I have a particular appreciation for and interest in appropriate workplace conduct that goes beyond what is legally compelled.
04 // WHAT KEEPS YOU UP AT NIGHT?
The Chicago Cubs inability to win during my lifetime. I try not to take my work home with me, but I do worry a lot about how to raise the profile of ethics and compliance concerns in a Company that is as decentralized and international as ours and that, thankfully, has not had a major compliance failure.
05 // IS THERE ONE SPECIFIC PIECE OF ADVICE THAT YOU COULD SHARE THAT YOU WISHED YOU HAD KNOWN WHEN YOU FIRST GOT THE JOB?
Be realistic in your objectives. It’s easy enough to read the Federal Sentencing Guidelines and the wealth of other material that’s out there on how to build an ethics and compliance program and then create a plan. It’s quite another thing to get it all done. You have to try to understand the culture of your organization- what people will be willing to accept, what they can be convinced of, and what they will reject outright. Take your wins where you can get them, and be patient with the rest. I’m learning every day.
06 // WHO DO YOU REPORT TO? WHAT ROLE HAS HE OR SHE PLAYED IN THE COMPLIANCE AND ETHICS PROGRAM?
The General Counsel, whose support for our program has been unwavering. Without the thought leadership and resources that he and the Chief Financial Officer have contributed to these efforts, we would not have been able to accomplish what we have.
07 // WHAT’S THE DUMBEST (OR SMARTEST) QUESTION THAT SOMEONE HAS EVER ASKED YOU IN AN INTERVIEW, AND HOW DID YOU ANSWER IT?
I’m not sure about the dumbest question, but the dumbest answer I ever gave was an honest response to the question why I wanted the job. I told the interviewer that I wasn’t sure that I wanted the job; that I was there to learn about them as much as for them to learn about me. Interviewers don’t want to hear that; they just want you to tell them that their job is the greatest thing since sliced bread.



February 3rd, 2010 at 11:07 pm
I enjoyed your blog, come check out mine sometime.
November 23rd, 2009 at 9:36 am
It sounds like you’re creating problems for yourself by trying to solve this issue instead of looking at why there is a real problem in the first place