Meghan O'Keefe Compliance & Ethics Advisor Integrity Interactive

Companies with global operations must globalize their compliance risk-management programs. The step is no longer optional. Here’s some good news however: globalizing your company’s compliance program can be easier than most senior operating executives imagine (and substantially easier than many compliance and legal advisors will admit).

Sure, globalizing your compliance and ethics program has its challenges. Company directors and senior operating executives are trained to spot risk and anticipate failure. Literature on the subject is daunting: you’ll face challenges with culture… you’ll struggle with languages… you’ll never get a handle on employee records…technological standards and platforms vary wildly from region to region. If you listen to the professional chatter and conventional wisdom on the subject of global compliance, you’ll never get started in the first place.

There is a better way. Company directors should not be defeatist when it comes to globalizing compliance risk-management programs. Directors can and should encourage their operating executives and legal advisors to turn this big problem into a small one. Directors can help operating teams let go of their fears, and concentrate instead on getting the fundamentals right. Your company might not solve every challenge when globalizing its compliance effort, but if it sticks to the basics, it will be miles ahead of the competition.

Company directors can point the way by encouraging operating executives to concentrate on three operating fundamentals: communicate ideas; collaborate with colleagues; and commit for the long-haul. When it comes to global compliance, here’s what operating executives need to know and do:

Communicate

Don’t assume that everyone knows the goals of your compliance and ethics program. Those individuals who are tasked with promoting, sustaining, and tracking a global culture of compliance and ethical behavior cannot take for granted that the rest of the world knows or even understands their objectives.

Set your tone from the top, and share it worldwide. Through increased communication, get your management team behind you on a global level. This process is not only practical, it’s scaleable.

On a very basic level, get people talking to each other. Establish a network of information by promoting monthly conference calls and ‘advertising’ the program in the company newsletter and other communication tools. Encourage continued global participation by keeping colleagues informed. Send emails with program objectives and status updates.

If resources allow, send Compliance and Ethics resources to international locations to garner support and strive to immerse individuals around the world in the process.

Liz Claiborne Corporation communicates…

Prior to launching its Code of Conduct program to Liz Claiborne’s operations in China, Daryl Brown, Vice President Global Ethics & Business Practices, traveled to Liz Claiborne’s offices in Hong Kong. There, she presented her program initiatives to a global team. By providing her colleagues with a general understanding of the design and content of the program, they were able to ask questions and provide feedback.

As a result of this worldwide conversation, Brown learned how the program would best resonate with her overseas audience: these communications helped determine the necessity of having the English content translated into two different Chinese dialects. Brown avoided “trial and error” by seeking guidance through communication; this sharing of information allowed Liz Claiborne’s Code initiative in China to be both effective and well received. The Liz Claiborne Corporation continues these efforts with focus groups, which meet regularly to exchange ideas and stay on target.

Collaborate

Don’t go it alone. Pay heed to the obvious: having the support of colleagues within your organization who understand your employees in France will increase your chances of succeeding in France.

Put a global team together and work with what you have. Although your North American efforts might be headed up by an experienced Compliance professional, don’t underutilize global employees who might play a different everyday role within the organization. Form compliance committees and compliance networks to promote this collaborative environment.

When you establish a diverse global team, come up with a plan together. Hear each other out on the nuances, but focus on efficiency. Although companies can’t often compromise on legal requirements and ethical values, they can compromise on tone, delivery, and methodology.

Chesapeake Corporation Collaborates…

Mike Beverly, Assistant General Counsel at Chesapeake Corporation, realized the importance of global participation from the onset of his Global Code of Conduct initiative. His core team comprises individuals based in both the U.S. and Europe, with titles ranging from Assistant General Counsel to Director of Information Systems. Through monthly meetings, Chesapeake has created a forum wherein the team shares their ideas of what will work and what won’t - from a content perspective to a systems perspective.

Team input at Chesapeake has impacted such decisions as when to best position training in accordance with cultural calendars, how to work together to parse out employee risk areas, and how to incorporate cultural sensitivities into targeted content.

Commit

Once you establish a network of communication and a collaborative team, dedicate resources committed to the program for the long-term.

You must invest in information technology and orchestrate IT resources globally. Investing in IT resources might create an upfront expenditure, but the long standing benefits will make your program sustainable.

You must devote compliance professionals to steer the program and to stick with it. Manage your resources internally and engage outside resources that can facilitate your objectives. Encourage your global team to meet regularly, and keep everyone on the same page.

The Coca-Cola Company Commits…

In her role within the Ethics & Compliance Office at The Coca Cola Company, Susan Montgomery supports Chief Ethics and Compliance Officer, Mark Snyderman, and manages the Company’s ethics and compliance web-based training program with a focus on the fundamentals. Although she won’t deny day–to-day challenges, Coca Cola’s program has achieved success through a daily commitment to working collaboratively with Coca Cola’s operations around the world.

Montgomery has pulled together a successful team of global resources, from subject matter experts to data and systems administrators. Working with this global team of up to twenty members, Montgomery dedicates time to maintaining their involvement in the program. She keeps her contacts informed on a monthly basis by sending detailed reports reflecting the status of all global employees. She’ll be the first to tell you that “local ownership is key.” She regularly encourages a continued flow of information, which helps keep everyone committed and engaged in the process, as employees overseas can see the results of their program first-hand.

A collaborative team might not appear overnight, but it will grow and strengthen if you follow basic instincts. “Sitting in Atlanta, I can’t rely on email alone to coordinate efforts with my colleagues around the world,” says Montgomery. “Picking up the phone and calling my contacts directly goes a long way.” Through time, as Montgomery develops and maintains these relationships, she is better able to rely on her resources.

Through commitment and team work, Coca-Cola’s global program only strengthens with time. In 2007, Coca-Cola’s program will expand from five languages to eight languages. Reflecting on a recent conversation she had with an overseas colleague, Montgomery says it best: “Getting your first initiative out the door is the hard part…it only gets easier from there.”

Conclusion: Directors Can Provide Perspective

It is imperative that Company directors help senior executives understand that a global compliance and ethics program is attainable if resources are focused with an eye towards common sense and the fundamentals.

Your company may not achieve immediate perfection, but through communication, collaboration, and commitment, you will achieve success.