CEOs may set the ethical tone from the top, but they need a supporting capable 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?

01 // TELL US WHAT YOUR GROUP IS FOCUSED ON THESE DAYS.
We’re particularly focused on the structural, legal, and cultural challenges of establishing and maintaining a rigorous ethics and compliance program in a multinational corporation with 87,000 employees operating in the U.S. and many foreign countries. Time Warner consists of a corporate headquarters and several operating divisions, each with its own CEO, CFO, general counsel, and compliance officer. This is a great strength in many ways. But each division has its own business profile and culture, and the compliance program must adapt to those differences while remaining unified in its essentials. The sheer number of our employees poses a similar set of challenges. As a global company, Time Warner’s commitment to ethics and compliance transcends national boundaries, and must respect legal, ethical, and cultural requirements in many locations.

02 // ARE THERE ANY PARTICULAR INITIATIVES THAT YOU HAVE FOUND WORKED WELL AND YOU WILL SHARE WITH OTHERS?
We make efforts to learn the business, socialize new programs and solicit feedback before implementing them, and to persuade rather than direct. In dealing with new initiatives, I have tried to adopt a three-part approach: First, articulate a general principle and persuade others it is the right principle and is in their interest to adopt it. Second, do the advance work to provide an easy–and financially feasible–way to implement that principle effectively. Third, allow others the freedom to implement the principle in their own way, as long as their approach is essentially consistent with the overall effort.

03 // WHAT IN YOUR BACKGROUND HAS MOST PREPARED YOU FOR THIS POSITION?
As a former prosecutor, I know many of the governing laws and rules and I understand how civil and criminal law enforcement, authorities and regulators approach the question of business conducts. That perspective is extremely valuable in today’s world. As a former manager in government, I learned how bureaucracy functions. I was surprised to find that the management skills I learned at the Justice Department translated so readily into the corporate world. Having worked in national security both before and after Sept. 11, 2001, I know how to make hard decisions and stay focused in a crisis.

04 // WHAT KEEPS YOU UP AT NIGHT?
The good thing about working in ethics and compliance and in the corporate world generally, is that by and large, decisions you make don’t mean the difference between life and death for large numbers of people. But the issues are very serious. I think we have a good program, and good employees, but we’re so large and diversified there is a lot of ground to cover.

05 // WHO DO YOU REPORT TO? WHAT ROLE HAVE THEY PLAYED IN THE COMPLIANCE AND ETHICS PROGRAM?
In addition to being Chief Ethics and Compliance Officer, I am also Deputy General Counsel, with additional responsibilities outside the area of ethics and compliance. I report to the General Counsel of Time Warner, Paul Cappuccio. Paul has been extremely supportive of my efforts, backing me with the CEO and the board of directors.