CEOs may set the tone from the top, but they need a capable supporting cast to tend to the day-to-day implementation of the company’s compliance and ethics programs. What are these leaders on the front lines talking about and doing these days?

Rod Willis: Vice President, Human Resources, Thales North America, Inc.	Dominique Lamoureux: Vice President, Ethics and Corporate Responsibility, Thales

E: Can you please explain how you became involved in Thales’ ethics and compliance program and what best prepared you for your current position?

RW: This is my first foray as a chief ethics officer – I’m also the human resources officer here for Thales North America – but I find many aspects of my human resources management experience is parallel to the values that you would find in ethics and compliance tenants at Thales. Values related to integrity and candor and transparency. Having spent 30 years or so in human resources, leadership and management is very much in keeping with what I’ve been charged to do in terms of creating focus for ethics in the U.S.

DL: I’ve been in charge of the export control policy of the group for about 20 years. I’ve been in charge of transparency and anti-corruption policies since the end of the 1990’s. As you know, export control issues and anti-corruption issues are a major risk for a defense company, particularly an international defense company. This experience has helped give me a good knowledge of the company, a wide scope of what is at stake and understanding of what the challenges and ethical issues are for us.

E: From a U.S. Perspective, Rod, or from an international perspective Dominique, what is unique about Thales’ business culture and its ethics and compliance program compared to its peers?

RW: With somewhat new eyes here for me, a lot of this has been a discovery and I’ve been pleasantly surprised. I worked for three international organizations and I’ve not seen one that is as well grounded in its principles than Thales is.

The expectations of ethical behavior are established early on here. All of our U.S. operations include an intro to ethics as part of the on-boarding process of new hires, including an introduction to the ethics officers and the procedures and processes they need to employ should they need to do that.

Last year in North America we did what’s called a welcome convention, where we gather those that we hired in a given time frame, typically 12-18 months, and provide a broad overview of what Thales is all about. Not just their country but Thales group as a whole. As part of that there is a presentation about ethics. So we grab them early, set the expectations, discuss principles, and make sure they understand their obligations in whatever role they play for us here at Thales. It continues throughout their employment and career here.

DL: These welcome conventions occur around the world for newcomers to Thales. I was invited to give a speech on business ethics in the U.S., and there was a convention last week in India, we had one in Asia, and we had one in Australia four months ago. These conventions introduce our Code of Ethics, all the different websites, corporate websites, national websites, and so forth relating to our ethics and compliance policies. We also use deployment of e-learning, a large program on business ethics that occurs three times for 30 minutes, that we have progressively deployed all over the world for all Thales employees.

E: Because you are such a global company, how do you deal with cultural differences that may result in different views on business ethics between the various territories in which you operate?

RW: The beauty of this organization is its flexibility and how it addresses not just ethics but business in general. The challenges that I see most often are cases where we may have folks on temporary assignment that may come from some other country, or those who may be in expatriate status. They may not be familiar with the law of the land, either in terms of ethics and compliance or in terms of their day to day dealings with managers.

So what we do is two things: depending on how much they know and understand we provide a primer on the fundamentals of operating as a manager as required in the
U.S. (basically employee law or employee relations law). So we enroll them just like we would anyone else in the U.S. for Thales, though they get training on a more specific basis as it relates to their specific job requirements if you will, and again on a broader basis in terms of our business ethics and compliance requirements.

DL: Compliance is a pure and complicated respect of domestic laws. You abide by your domestic laws, and this is, of course, our policy in each country where we operate. What we consider ethics is what we have to develop when laws are not homogenous and when the law does not give you the necessary answer. Then you have to develop standards of ethical business conduct.

So it’s not simple, it’s a real concern, but we develop this global ethics conduct on a world wide basis. This code of ethics has been designed, written, corrected and so on by all the ethics officers of all the different countries in which we operate. So we asked and received change from ethics officers from the U.S., the UK, Netherlands, Germany, France and so forth. This was something that everybody could share in.

The code is also developed and promoted at country level, because different policies can become a very cultural issue. For instance, in some countries the whistle-blowing hotline would be easy to use; people will be comfortable picking up a phone and calling. In other countries, people are not quite as comfortable with the idea of whistle-blowing. So we think globally but really act locally.

RW: Regarding whistle-blowing, employees here have two ways to bring issues to the table: directly to their ethics officer, be it at my level here at Thales or at their division ethics officer, or to their supervisors or managers. And if none of those work we have a hotline that is anonymous that they can pick up their phone and call.

Yesterday, I got a call from an employee asking me a question around conflict of interest. I was thrilled to get it because it said to me that our message around transparency and doing the right thing by our employees and by our company is sinking in and it’s real. It’s lived everyday and they understand it, so when they encounter a situation they’re not sure about they feel free enough to pick up a phone and call me.

E: What knowledge or tools have you developed through learning from other organizations that have developed strong ethics and compliance programs?

DL: Thales is part of an initiative called Common Industry Standard that we have designed with our European colleagues. Working with all the large European aerospace and defense companies, we have developed and share a common industry standard for several ethics related programs such as Codes of Conduct and, particularly, tools to help
fight against corruption. This has been approved by national governments and now by companies themselves.

We recently have begun distancing ourselves from those in the aerospace and defense industry that only have a U.S. common standard or European common standard. We are developing the first trans-Atlantic industry standard and to go world wide. We hope to roll out this standard soon.

RW: I think there are some hallmarks that are clearly evident not only in Thales but in any organization that has a robust ethics program. It’s important to understand that Thales approach to ethics is the same rigorous manner as it does other dimensions of its business operations. It’s no less important than anything else. It’s serious business for us, it’s important to us and in the long run if you do anything less it would be a disservice to all involved, from our Chairman to our stakeholders, our customers and our employees.

In the long run Thales recognized a long time ago that it makes sense for us to do the right thing for our people, for our employees, for our stakeholders. I think when you look in very comprehensive ways, as Dominique has shared, at the things that Thales has done over the decades, it really does say that we have had a visionary approach to ethics long before many companies did, we’re doing an awful lot that is voluntary in nature because it’s the right thing to do.